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My thinking is that they would go to almost zero effort disallow such an assessment.

Keep in mind that it takes almost zero effort to disallow pretty much anything on a tax return. All the auditor has to say is that figure is one used for property tax purposes and by it's nature does not necessarily reflect the FMV of the property.

In some areas, the real estate tax assessment does not have to reflect market value. For instance, in my area an assessment can remain unchanged as long as the average assessment for all property in the tax district is within 15% of FMV. Then there is Nassau County on Long Island. I'm not sure if this is still true, but it used to be that the assessment was based on the construction cost in 1936, regardless of when the structure was built.

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