City of Alexandria v. Richmond, Fredericksburg & Potomac Railroad

Does a circuit court have jurisdiction to entertain an application filed under Code § 58-1145 by a public service corporation to correct a local real estate tax levy on the ground the underlying evaluation made by the State Corporation Commission (SCC) was erroneous? Two circuit courts have entered diverse judgments on that question, and, in combined appeals, we are asked to resolve the conflict.

In Virginia, real estate is “segregated for, and made subject to, local taxation only, and shall be assessed for local taxation in such manner and at-such times as the General Assembly may prescribe…