841 Associates v. Board of Revision of Taxes of City & County of Philadelphia

PELLEGRINI, Judge.1

841 Associates (Taxpayer) appeals from an order of the Court of Common Pleas of Philadelphia County (trial court) determining that Taxpayer’s property had a fair market value in 1994 of $32.5 million. This case presents a pure legal issue of whether a trial court may, in a de novo review of the fair market value of property in a tax assessment challenge, accept only part of the Taxpayer’s expert testimony, but not the valuation, when the taxing authority fails to present rebuttal evidence.

Taxpayer owns a 14-story office building located at 919-841 Chestnut Street in…