PSNH, an electric utility company, sought abatements of taxes assessed against it located in the city. The city denied the abatements. PSNH appealed to the Board of Tax and Land Appeals (BTLA), with both parties stipulating to the aggregate assessment of PSNH’s property, including an office building.
The BTLA compared the stipulated aggregate assessment with the City’s expert’s opinion of aggregate fair market value of PSNH’s property and concluded that the City over-assessed PSNH. However, the City’s expert – and, subsequently, the BTLA – excluded the office building from its valuation of PSNH’s property
On appeal the New Hampshire Supreme Court, agreed with the town that the BTLA’s calculations were unjust and unreasonable. As such, the Court remanded the case with the instruction that the aggregate fair market value should include the fair market value of the office building.