Supervisor of Assessments v. STELLAR GT

BATTAGLIA, Judge.

In order to determine the value of a piece of real estate upon which its tax is derived, the Maryland State Department of Assessment and Taxation assesses1 real property once every three years; any increase in the value is “phased in”2 over a period of three years. See Section 8-103 of the Tax-Property Article, Maryland Code (1985, 2001 Repl.Vol.).3 The property is valued as of “the January 1 immediately before the 1st taxable year [4] to which the assessment based on the new *662value is applicable” or the “date of finality,” which is the date that “assessments become final for…