Can a Company's Tax Assessment Be Increased Based on the Testimony of the Board's Expert ?
In Pittsburgh-Des Moines Steel Co., Pittsburgh-Des Moines Steel (PDM) owned six parcels of land composed of 59.595 acres on which was located a steel manufacturing plant.
At trial the board's expert used the sales comparison approach for valuation and testified that, in his opinion, the highest and best use of the subject property was a heavy assembly operation by a single user similar to PDM.
The trial court increased the tax assessment based on the expert's testimony.
On appeal, PDM argued, inter alia, that the board's expert employed the value-in-use method in reaching his opinion of fair market value.
However, the record indicated that the expert did not indicate that he based his opinion of value solely on the value of the property to PDM.
In fact, the record contained no mention of this impermissible technique before PDM's attorney discussed it in his closing argument.
Therefore, this Court concluded that the evidence did not support PDM's contention that the expert employed the value-in-use method.