Under Indiana's true tax value system, the assessed value of nonagricultural land is based, theoretically, on its approximate market value. Town of St. John et. al v. State Bd. of Tax Comm'rs, 665 N.E.2d 965, 967 (Ind. Tax Ct. 1996) (St. John I) rev'd on other grounds by Boehm v. Town of St. John, 675 N.E.2d 318 (Ind. 1996). Those values are compiled and reflected in the county land orders and are applied to various geographic areas, subdivisions, or neighborhoods based on distinguishing characteristics or boundaries. IND. CODE 6-1.1-4-13.6; IND. ADMIN CODE tit. 50, r. 2.2-4-4. The Court will reverse a State Board final determination only if it is unsupported by substantial evidence, constitutes an abuse of discretion, exceeds statutory authority, or is arbitrary and capricious. In order to establish a prima facie case that its land was improperly assessed under the Land Order, it was required to make a two-prong showing that: (1) comparable properties. (2) were assessed and taxed differently.