I think it was deliberate.

[ECL213]

49. Every county is different...

Many counties set a percentage of the fair market value at which they assess the property. My county assesses property at 66% of the FMV, so if they say my property's assessed value is $200K, then they have determined the FMV is $300K, roughly.

Some counties use 33%, other just use 100%. It's all over the map.

A lender would be looking at the FMV, though. They sure as shit aren't going to take my word for it if I'm trying to get a loan.

This case, though, isn't just about how Dipshit Donnie valued Mar-A-Lago. That's just what his people are using to deflect from the other 199 instances where the NY AG says he fraudulently fudged his numbers. It's all part of a "pattern and practice" of fraud including:

Representing that Mr. Trump had cash on hand that he did not;
Ignoring critical restrictions that would significantly lower property values when setting valuations;
Changing the methodology used to value properties from year to year, without reason or notice;
Using vastly different methods to value different properties even in the same year; and
Including intangible items, such as brand premiums, when calculating an asset’s value, despite representing in the statements that such items were not included.