Tax Assessment – Business Personal Property Valuation

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Morgan County Bd. of Equalization v. Indorama Ventures Xylenses & PTA, LLC, [Ms. SC-2023-0183, SC-2023-184, Mar. 22, 2024] __ So. 3d __ (Ala. 2024). The Court (Mitchell, J.; Parker, C.J., and Shaw, Bryan, and Mendheim, JJ., concur) affirms the Morgan Circuit Court’s judgment in favor of the taxpayer in a dispute concerning valuation of a petrochemical plant and related business personal property.

The Court holds that in determining fair-market value, the circuit court properly considered “all the evidence” pursuant to § 40-3-25, Ala. Code 1975 and was not limited to considering the method (mass-appraisal cost approach) used by the Board of Equalization. Ms. *12. The Alabama Personal Property Appraisal Manual “does not – and cannot – supersede a court’s statutory obligation to determine the fair and reasonable market value of the property based on ‘all the evidence,’ § 40-3-25.” Ms. *13.

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