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binding on this Court. We recognize, however, that the
definition of highest and best use set forth immediately above is
consistent with the principles of Frazee v. Commissioner, 98 T.C.
554 (1992); Symington v. Commissioner, supra; and Stanley Works &
Subs. v. Commissioner, supra.
a. Parcel A
Young and Dilmore both concluded that the highest and best
use of parcel A on the date of decedent's death was commercial in
nature. Tidwell and Hearn, on the other hand, disagreed and
concluded that, as of the date of decedent's death, the highest
and best use of parcel A was residential in nature. The
classification as either commercial or residential is significant
because such classification is directly related to the appraisal
value of the property. More specifically, with other factors
remaining constant, the value of commercial real estate generally
exceeds the value of residential real estate. Respondent's
determinations rely upon the Young and Dilmore conclusions, while
petitioner’s argument is based upon the Tidwell and Hearn
conclusions.
Much of the present dispute involves the zoning
classification of parcel A as of the valuation date. As of the
date of decedent's death, February 20, 1987, roughly half of
parcel A was within the city limits of the city of Birmingham,
Alabama. The remaining portion of parcel A was located outside
the corporate limits of the city and in Jefferson County,
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