Why, yes, that's correct, but there is no need for a "comparable" value when you have the ACTUAL value which is a sale price on the open market between a willing buyer and seller. If you buy your house for $500,000,
that is the FMV, because that's the price between willing buyer and seller. It doesn't matter what the house next to you sold for 5 years ago, because FMV is established by sales between willing buyers and sellers. Surely you know this. You cannot (unless you've got great lawyers, apparently) protest your property tax bill by arguing the property you paid $500k for is only worth $250k. But that's what CVS and Walgreens are doing, precisely.
My example was real, here's the case:
https://law.justia.com/cases/wisconsin/court-of-appeals/2016/2015ap000876.html
The court literally held that FMV as determined by actual purchases of land and construction prices and rent weren't FMV, and that a sale of the building didn't reflect FMV. It concludes with almost no discussion except hand waving that the value between buyer and sellers is inflated, as are rents, and it disregarded cost of construction. It's like reading something from another reality. CVS bought a building and land for about $2 million, tore down the existing structure, then spent another $2 million to construct the store, then sold that building and land for about $4.5 million once the store was completed.
That's FMV - either the cost of the building (their total cost in the structure and land was roughly $4 million) or the selling price ($4.5 million) is literally how FMV is determined - comps are only used when those direct approaches aren't feasible. CVS argued the value of something CVS paid $4 million to build was....< $2 million, and the value of something they sold for $4.5 million was < $2 million. It's surreal that the court AGREED.