Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix - Page 36

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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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