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~Uft i5 '94 16:33 PARKER POE ADAMS 9i'9 8~8 0564 P.4 <br /> <br /> Under the guidelines of AMP, Supra, the Taxpayer has the burden of <br /> establishing: (1) that the County employed an arbitrary or illegal <br /> method of appraisal a .r~.. (2) that the value assigned by the County Soard <br /> was substantially greater than the true value in money of the~ property as <br /> of January 1 for the years in question. The Co~mission examined these <br /> two issues separately with regard to the real p~6per~y and personal <br /> property values assigned by the County Board for each tax year under <br /> appeal. Where the County contends that the true value in money of real. <br /> or personal property for any year was higher than the value assigned by ' <br /> the County Board, the County has the sa~e burden of proof as that imposed <br /> on the Taxpayer. This burden ks consistent with the ruling of the <br /> C~'~..tssion in Olde ~eau General Partnership v. Alleghany County, 92 PTC <br /> 541, entered 29 Dece~ber 1993. <br /> <br /> sti~ulations <br /> <br /> Exhibit A of the pre-hearing order sets forth certain u~disputed <br />facts, which are incorporated by reference and are part of the basis for <br />the C~,,,.ission' s decision. <br /> <br /> Evidence <br /> <br /> The evidence offered by the Taxpayer and admitted by the C~,,,lission <br />consisted of the following: <br /> <br />1. Taxpayer Exhibits A through F - Exhibit B - Pre-hearing Order. <br /> <br />2. Taxpayer Exhibits H and I - Exhibit B - Pre-hearing Order. <br /> <br />3. Taxpayer ~xhibit N through P - Exhibit 8 - Pre-hearing Order. <br /> <br />-3- <br /> <br /> <br />