Opinion
January 25, 1988
Appeal from the Supreme Court, Queens County (Kassoff, J.).
Ordered that the judgment is affirmed, with costs.
As a general rule, an actual sale at arm's length, if recent and not explained as extraordinary, is the best evidence of value for tax assessment purposes because it is directly reflective of the property's market value and does not require the court to engage in speculation (Matter of Southern Westchester Assocs. v Assessor of City of Yonkers, 122 A.D.2d 212). However, the circumstances surrounding the two recent sales of the subject property justify the trial court's conclusion that those sales are of little or no probative value (see, Matter of Rice v Srogi, 70 A.D.2d 764; Matter of Montague Assocs. v Boyland, 19 A.D.2d 742).
In addition, the court did not err in placing little weight on the petitioners' expert's appraisal, as the appraisal report contained inconsistent and unexplained conclusions which were not supported by the facts, figures and calculations relied upon to reach those conclusions (see, 22 NYCRR 202.59 [g] [2]; Matter of Johnson v Town of Haverstraw, 133 A.D.2d 86). Thus, the petitioners failed to meet their burden of proving by substantial evidence that the assessments were excessive (see, Matter of Adirondack Mountain Reserve v Board of Assessors, 99 A.D.2d 600, affd 64 N.Y.2d 727; Mobil Oil Corp. v Tax Commn., 60 A.D.2d 910). Mollen, P.J., Thompson, Lawrence and Eiber, JJ., concur.