South Carolina Tax Commission v. South Carolina Tax Board of Review

Gardner, Judge:

The respondent Baker and Baker (Baker)1 is a South Carolina general partnership which owns an office building in Columbia, S. C. Approximately 61 percent of the net rental space of the building is leased by long-term leases to a utility and for this reason the property was appraised for ad valorem taxes by the South Carolina Tax Commission. All parties admit that the utility leases were entered into at arms length and that the rental was fair and reasonable when the property was leased. The South Carolina Tax Commission appraised the property for 1980 ad valorem taxes as having…