In Re the Appeals of Southern Railway Co.

EXUM, Justice.

This is an ad valorem tax case in which petitioners, Southern Railway Company and Norfolk Southern Railway Company,1 *179hereinafter “Railroads,” challenge the Property Tax Commission’s, hereinafter “Commission,” appraisal of their companies’ market value. The Court of Appeals affirmed the Commission’s decision. We conclude the Commission erred in ruling that the Railroads failed to rebut the presumption of correctness accorded the appraisals of the Department of Revenue, hereinafter “Department.” We also conclude the Commission erred in adopting certain appraisal methods used by…