This was a proceeding in eminent domain to acquire title in fee simple absolute to certain real property. The court found the value of the properties to be $2.4 million. The assessed valuations of the land for the three prior years for taxation was $1.1 million. Naturally, D was extremely upset as it had no desire to pay the higher fees. The owner of the property had sworn to D that the value of the land was $1.1 million when being assessed for taxes.

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