County Board of Arlington County v. Commonwealth

In this appeal, we decide whether the State Tax Commissioner’s assessment of railroad real estate based upon an appraisal technique known as the “unit method” is consistent with the provisions of Article X, § 2 of the Constitution of Virginia. As pertinent, that section provides: “[a] 11 assessments of real estate and tangible personal property shall be at their fair market value, to be ascertained as prescribed by law.” Id.

In general terms, the unit method, as applied in this case, involves an appraisal of all railroad property as a single operating unit or a “going concern.” The railroad’s…