Which of the following statements is false?

A.The apportionment 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.There is an opportunity for tax planning in basis apportionment.

D.The Tax Court has held that the allocation of basis must be made at the time of purchase rather than at the time of sale.