Proving Disproportionality Requires a Taxpayer to Establish its Aggregate Valuation is a Higher Percentage of Fair Market Value than Property in the Municipality Generally
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.