102 MISC. PUBLICATION 218, U. 8S. DEPT. OF AGRICULTURE 
Supreme Court of New Hampshire in reference to a case involving 
this point: 
The price at which it [a parcel of real estate] was sold or leased at any former 
time is evidence only so far as its proof of a former value tends to show the price 
for which it could have been sold for the first day of April [the assessment date]. 
The use of sales considerations by mathematical rule with no room 
for exercise of judgment may also give unsatisfactory results, even 
though considerations realized in forced sales are excluded. Many 
sale values may be more or less unrepresentative of the statutory 
standard of value prescribed for assessment on account of circum- 
stances affecting those particular sales. Therefore, unless the prop- 
erties sold in free market transactions are fairly representative of the 
district and constitute a large enough sample so that minor variations 
in the values realized offset each other, the use of these unadjusted 
values will be misleading. This subject is discussed at length in a 
report of the Wisconsin Tax Commission, which concludes with 
reference to a mechanical sales method which had formerly been in 
use for the purpose of equalization: 
As a consequence of these defects in the sales method referred to above it was 
officially abandoned by the commission in 1925. This does not mean that sales 
were abandoned as a basis for property valuation. On the contrary, the effort 
was made, by a more critical and intelligent use of sales, to get back more closely 
to the statutory provision that property should be assessed at what it will ordi- 
narily bring at private sale and to recognize that this statutory standard applies 
with as much force to assessments of taxation districts made by the county 
board and assessments of counties made by the tax commission as to assessments 
of the property of the citizen made by the local assessor (58, Rept. 1930, pp. 17-18). 
Not only are knowledge of valuation factors and sound judgment 
required if satisfactory results are to be obtained through use of 
information in regard to sales, but there must also be a sufficient 
number of sales to establish a market. Most kinds of real estate are 
transferred frequently enough for that purpose. Where the market 
values are erratic, as sometimes happens, especially in the case of 
cut-over forest lands, more judgment is required in appraisal, and 
the results are less certain than where the market values are stable. 
However, certain kinds of real estate are sold so seldom under condi- 
tions establishing value that it can fairly be said that no market for 
them exists. Oper ting mines and public-utility properties are sub- 
ject to this difficulty. In these cases, recourse must necessarily be 
had to other evidence, including all the available facts that might 
be presumed to be in the minds of sellers and buyers. In these cases 
a formula involving such facts may often be a useful aid in estimating 
value. In any case, the appraisal should aim at the value that would 
be determined in an actual and fair market with free competition 
between willing sellers and willing purchasers. 
The application of sale prices to the assessment of real estate 
involves the question of the relation between the values of large 
and small tracts when there is no market for the large tracts and 
only a limited market for land of the same character when sub- 
divided. Recently a Louisiana district court was called upon to 
make a decision on this point with respect to a large tract of cut-over 
land. It was held by the court that the land should be valued as 
the owner actually holds it, that is, at the amount it would sell for 
in the wholesale market. The selling price of a few small parcels 
34 Railroad v. The State, 60 N. H. 142. 
