- 55 - 1985 and that several factors show that parcel 1 was the most valuable of the three parcels when they were purchased. Generally, “We do not consider that the amount for which the property was assessed for purposes of local taxation is necessarily a reliable criterion to be used in estimating its fair market value.”34 Frazee v. Commissioner, 98 T.C. 554, 563 (1992). However, in appropriate circumstances tax-assessed values can be useful as a guideline or as corroboration of other evidence of fair market value. Kellahan v. Commissioner, T.C. Memo. 1999-210. And, in the case that we are concerned with the relative values of several parts of a larger piece of property, local tax assessments may be relied upon to provide the correct value of a particular parcel of real estate. 2554-58 Creston Corp. v. Commissioner, 40 T.C. 932, 940 n.5 (1963).35 We are not willing to conclude as a matter of law that because respondent’s determination is based on local tax assessments, it is arbitrary. And, indeed, respondent’s determination appears reasonable and consistent with the relative sizes of the three parcels. See 34This is especially true when there is nothing in the record indicating that the tax-assessed value was intended to represent fair market value. Kellahan v. Commissioner, T.C. Memo. 1999-210; Estate of Dowlin v. Commissioner, T.C. Memo. 1994-183; see also sec. 20.2031-1(b), Estate Tax Regs. 35In 2554-58 Creston Corp. v. Commissioner, 40 T.C. 932, 940 n.5 (1963), we stated: “Although valuations for real estate taxes may often be too low to be relied upon as furnishing the correct value of a particular parcel of real estate as a whole, we have no reason to reject the use of such valuations in determining the relative value of land and buildings.”Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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