Which of the following statements is false?

A. Theapportionment of basis must reflect differences in relative fair market values of parcels being sold if such differences exist.

B. Equitable apportionment means ratable apportionment on a pro-rata basis.

C. Th ere is an opportunity for tax planning in basis apportionment.

D.TheTax Court has held that the allocation of basis must be made at the time of purchase rather than att he time of sale.