- 20 - contribution by petitioners. Cf. Estate of Spruill v. Commissioner, 88 T.C. 1197, 1233 (1987). There remains the assessed value for local property tax purposes of $1,000. The tax-assessed value of property is, in general, “‘not * * * necessarily a reliable criterion to be used in estimating its fair market value’”, Frazee v. Commissioner, 98 T.C. 554, 563 (1992) (quoting Estate of Lippincott v. Commissioner, 27 B.T.A. 735, 740 (1933)). This is particularly true when there is nothing in the record indicating that the tax- assessed value was intended to represent fair market value. See Frazee v. Commissioner, supra. However, in this case the record contains evidence that the tax-assessed value of property in this locality was approximately 80 percent of fair market value. The ratio study conducted by the State of South Carolina found that in 1990 the average ratio of tax-assessed value to sales price for nonresidential, nonagricultural property in Clarendon County was 79.4 percent. Respondent’s expert also opined that the tax- assessed value of property in South Carolina was approximately 80 percent of fair market value. Moreover, in appropriate circumstances tax-assessed values can be useful as a guideline or as corroboration of other evidence of fair market value. See Fannon v. Commissioner, T.C. Memo. 1986-572, modified and remanded without published opinion 842 F.2d 1290 (4th Cir.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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