William N. Kellahan, Jr. and Alice H. Kellahan - Page 20




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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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