Property Tax Alert–Georgia

December 2004

Under the income approach to establish the valuation of an apartment complex for Georgia property tax purposes, sufficient evidence was presented. Comparable sales data allegedly not presented before the county board of equalization but introduced at the superior court trial were permissible because they were tied to the assessors' income approach that was used throughout the appeal process. The trial court's admission of evidence regarding comparable sales during preceding years, and its exclusion of evidence of fair market value in a prior year, were within its discretion. A general objection to the admissibility of the senior appraiser's entire testimony as lacking verifiable certainty and scientific reliability, and a specific objection to the admissibility of his testimony regarding aspects of his income approach formula, were rejected because the objections were not made contemporaneously.

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