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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.
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