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that in Florida property tax values must be based upon a
"just valuation" of the subject property. See McArthur
Jersey Farm Dairy, Inc. v. Dade County, 240 So. 2d 844
(Fla. Dist. Ct. 1970)(citing (Walter v. Schuler, 176 So. 2d
81, 85-86 (Fla. 1965)).
In this case, the parties have stipulated that the
assessed value of the subject property "as of 1988" was
$472,640. However, the record does not support
petitioner's assertion that the subject property was
assessed at the same amount "in years 1988, 1989 and 1990".
In fact, the BAAS appraisal states that the assessed value
of the subject property was as follows:
Property Per Acre Per Acre Percent
Year Tax Value Gross 56.5 Dry 23.47 Change
1986 $267,560 $4,735.58 $11,400.09
1987 314,250 5,561.95 13,389.43 17
1988 833,000 14,743.36 35,492.12 165
1989 472,640 8,365.31 20,138.05 -43
Sale to the County
Petitioner argues that the sale of 4.83 acres of land
to Hillsborough County for approximately $20,000 per acre
is the "best evidence of fair market value" of the
decedent's property. According to petitioner, this sale
"was a negotiated sale between arm's length parties", not a
forced sale; it was made reasonably close to the valuation
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