Appeal of Mellon Bank, N.A.

Opinion by

Judge Blatt,

Mellon Bank, N.A. (taxpayer) ¡appeals here an order of the Court of Common Pleas of Allegheny County which assessed the fair market value on one of the taxpayer’s banks1 at 9 million dollars for the 1980 tax year and at 9% million dollars for the 1981 tax year.2

After an initial determination as to value by the Board of Property Assessment (Board), the taxpayer exercised its right of de novo review and appealed that determination to the court of common pleas. At trial, both the taxpayer and the City of Pittsburgh (City) presented expert testimony .relating to the value of…