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evidence in the record suggesting that county zoning commission
officials, or any other county officials for that matter, had any
involvement regarding the creation of this buffer zone.
Moreover, the record lacks conclusive evidence concerning the
reason the annexation stopped where it did. Petitioner’s
speculation with regard to the purpose and effect of the buffer
zone may indeed be plausible, but it is speculation nonetheless.
In recognition of this series of events, we conclude that at
the time of decedent's death there existed numerous indications
that the Highway 280 corridor was experiencing a northerly
progression of commercial development and that such progression
was extending beyond I-459. We further conclude that parcel A
was within the parameters of this expansion as of the valuation
date. Accordingly, we conclude that there was a reasonable
probability that parcel A could likely be rezoned to a commercial
classification within a relatively short period of time following
decedent's death. See Frazee v. Commissioner, 98 T.C. at 564.
To a lesser extent, the current dispute involves the
accessibility of parcel A. Respondent recognizes that parcel A
suffers from an accessibility standpoint. Respondent maintains,
however, that the extent of the accessibility problem is not
significant enough to warrant a finding that its highest and best
use is not commercial in nature. Petitioner disagrees and
contends that parcel A was so inaccessible as to preclude
commercial development. Accordingly, petitioner contends that
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