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SUN 15 '94 16:33 PARKER POE Ar,Al'IS 9'~'9 828 0564 P.4 <br /> <br /> Under the guidelines of A~., supra, the Taxpayer has the burden of <br /> establishing: (1) that the County employed an arbitrary or illegal <br /> method of appraisal and (~-) that the value assigned by the County Board <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 pr6Perty and Uersonal <br /> property values assigned by the County Board for ea~.h 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 same burden of proof as-that im[~gsed <br /> on the Taximayer. This burden is consistent with the ruling of the <br /> Cc.;,.ission in Olde Beau General Partnership v. Alleghany County, 92 PTC <br /> 541, entered 29 December 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 referehce and are part of the basis for <br />the Co~mission's decision. <br /> <br /> Evidence <br /> <br /> The evidence offered by the Taxpayer a~d admitted by the C~,,~,,ission <br />consisted of the following: <br /> <br />1. Taxpayer Exhibits A through F - Exhibit 8 - Pre-hearing Order. <br /> <br /> 9.. Taxpayer Exhibits H and I - Exhibit B - Pre-hearing Order, <br /> <br />3. Taxpayer Exhibit N through P - Exhibit B - Pre-hearing Order. <br /> <br />-3- <br /> <br /> <br />