Until they invoke PoED they can offer whatever they want for a property. It is only after they have invoked that they are required to pay a minimum of market value.
It is quite possible that the first offer was a fair or slightly low offer and the second an inflated offer. No one wants to invoke PoED. It is horrible PR and a lot of additional lawyer cost. In most cases the state will offer higher than market value just so they do not have to invoke. You just need to know how to play the game and when to accept before they get pissed and give you fair value (which in many cases is the assessed value which is often actually less than fair market value).
Keep in mind each time you agree to your tax bill you are also saying that is a fair value (not high or low) for your property. Cheating the system can come back to bite you. I saw it happen to a guy who bought a classic car once. Put down cost of purchase significantly lower than actual purchase price to save taxes. Totalled the car shortly thereafter. Insurance company gave him the recorded purchase price of the car and not a penny more.
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