In the Matter of Allred

LAKE, Justice.

The issues raised here on review are ones of first impression. The primary issue is whether the State Property Tax Commission (the Commission), while sitting in its appellate capacity as the State Board of Equalization and Review pursuant to N.C.G.S. § 105-290(a), is subject to the same statutory limitations as a county tax assessor (assessor) in adjusting appraised values of real property for ad valorem tax purposes. Secondarily, respondent Randolph County questions whether the sale of property occurring subsequent to that property’s octennial tax valuation is a factor which…