State Tax Commission of Missouri
IN THE MATTER OF THE 2007 AND 2008)
COMMERCIAL ASSESSMENT RATIO OF)
PROPERTIES IN ST. LOUIS COUNTY,)
)
Complainants,)
)
v.)Appeal No. 07-08 Ratio
)
JAKE ZIMMERMAN, ASSESSOR,)
ST. LOUIS COUNTY, MISSOURI,)
)
Respondent.)
DECISION AND ORDER
HOLDING
The State Tax Commission finds that the median level of assessment for commercial property in St. Louis County in 2007 is 29.4%.
PROCEEDINGS
The State Tax Commission was convened at an evidentiary hearing beginning on December 7, 2010.Complainants[1] appeared by Thomas Campbell, Attorney at Law. Respondent appeared by Edward W. Corrigan, Associate County Counselor. Taxpayers filed appeals with the State Tax Commission alleging overvaluation and discrimination.The issues of valuation of the subject properties and median level of assessment for commercial properties were bifurcated.[2]The State Tax Commission ordered all parties alleging discrimination in 2007 and 2008 to present evidence at this hearing regarding the median level of assessment for commercial properties.Complainants represented by Counsel Thomas Campbell were the only parties presenting evidence; therefore, any other claims of discrimination based upon being assessed at a ratio grossly excessive to the average 2007 commercial assessment ratio have been dismissed.Parties filed briefs on March 29, 2011; reply briefs were dated April 12, 2011.
ISSUE
The Commission heard evidence to determine the median level of assessment for commercial properties located in St. Louis County for 2007.
SUMMARY
The following exhibits were introduced and admitted into evidence:
Complainants’ Exhibits
EXHIBIT |
DESCRIPTION |
A |
Written Direct Testimony of Robert Gloudemans |
B |
Ratio Study of Robert Gloudemans |
C |
|
D |
Disk |
E, E1, E2 |
Disk |
F |
Standard on Ratio Studies |
G |
Disk |
H |
Disk |
I |
Disk |
Respondent objected to Exhibits A, B, D, E, G, H, and I. Objections overruled. [4]
Respondent’s Evidence
EXHIBIT |
DESCRIPTION |
1 |
Ratio Study of Patrick O’Conner |
2 |
Written Direct Testimony of Patrick O’Conner |
3 |
Written Direct Testimony of Michael Brooks |
4 |
Michael Brooks’ CV |
5 |
Commercial Sales Study |
6 |
CD sales packet for X, U, P & V properties |
7 |
Written Direct Testimony of Robert Bruns |
8 |
CV of Robert Bruns |
9 |
Written Direct Testimony of Cynthia Schneider |
10 |
Commercial Sales Summary Packet |
11 |
STC Ratio Study |
12 |
IAAO Ratio Study Standards |
13 |
Robert Gloudemans’ 2005 Study |
Rebuttal Exhibits |
|
R1 |
CD of Complainant’s Sales |
R2 |
|
R3 |
Spreadsheet of 315 Sales |
R4 |
Change of Assessment Notices 5/18/2007 |
R5 |
Board of Equalization Decisions |
R6 |
CD on 27 sales |
R7 |
Spreadsheet on 27 sales |
R8 |
Change Notice on 5/18/2007 |
R9 |
BOE decisions 27 Decisions |
R10 |
CD on 177 Sales |
R11 |
Spreadsheet on 177 Sales |
R12 |
Contract for Consulting – Gloudemans |
R13 |
Complainant’s Documents |
R14 |
Validity Codes |
R15 |
Written Direct Testimony Michael Brooks |
R16 |
Written Direct Testimony Patrick O’Conner |
R17 |
2007 Study PPRC |
R18 |
Testimony of Gloudemans in 2005 case |
R19 |
Testimony of Gloudemans in 2005 case p. 390 |
R20 |
Testimony of Gloudemans in 2005 case p. 404 |
R21 |
Testimony of Gloudemans in 2005 case p. 422 |
R22 |
Testimony of Gloudemans in 2005 case p. 450 |
R23 |
Part of Exhibit D |
R24 |
Testimony of Gloudemans in 2005 case p. 459 |
R25 |
Testimony of Gloudemans in 2005 case p. 551 |
Complainant’s Evidence
Mr. Robert Gloudemans testified on behalf of the Complainants.He is a partner in a consulting business specializing in property tax and assessment administration.Mr. Gloudemans previously worked for the International Association of Assessing Officers (IAAO) and the Division of Property Valuation with the State of Arizona.The consultant has experience in ratio related issues including development of the IAAO workshop on Fundamentals of Assessment Ratio Studies, authoring or contributing to numerous appraisal books, and developing standards for ratio studies for IAAO.
Mr. Gloudemans completed a ratio study for the 2007 assessment year in St. Louis County.For his study, he was assisted by the Public Policy Research Center (PPRC) at the University of Missouri-St. Louis.PPRC collected data from the Assessor’s Office regarding the assessments and sales of commercial property in the county.They did not verify the sales.
Mr. Gloudemans used the county’s data collected by PPRC and selected sales from
July 1, 2006, to June 30, 2007, a total of 1,071 sales.Out of the sales from that 12 month time period, he concluded 315 sales were usable for his ratio study.The criteria for selection were based upon the code assigned to the sale by St. Louis County.Mr. Gloudemans included sales coded as V (a certificate of value filed), X (sale confirmed with at least one party to the sale and is deemed a valid sale), U (sales verified by St. Louis County but involves more than one parcel), R (resale) and 1 (multiple parcel sales). Mr. Gloudemans eliminated parcels where the appraisal to sales ratio was 1.00 and outliers (2 parcels with very low ratios and 2 parcels with very high ratios).
Mr. Gloudemans used the valuation in the County’s assessment books as of September 2007.The valuation in the books as of that date would have included valuations set by the Board of Equalization (BOE). The total number of valuations as set by the BOE and included in the study is 27.(It does not include the number of sales excluded where the appraisal to sales ratio was 1.0 as the BOE set the value at the sales price.)
Mr. Gloudemans found an overall median ratio of 26.6%.When reviewed by property type, the median by type is:
Type |
% |
Median |
Office |
19.1 |
.286 |
Retail |
39.7 |
.266 |
Warehouse/Industrial |
19.2 |
.279 |
Miscellaneous Improved |
12.3 |
.242 |
Vacant Land |
9.7 |
.131 |
He used two measures of central tendency – median and weighted mean – and various weighting schemes.“Basically, the entire weighted mean is between 0.240 and 0.245.We conclude that the best estimate of the median assessment ratio is no more than 27% and the best estimate of the weighted mean assessment level is no more than 25%.”[5]
Respondent’s Evidence
Mr. Patrick M. O’Conner testified on behalf of the county.Mr. O’Conner is a Certified General Real Estate Appraiser licensed in Missouri and Texas. He has been involved in mass appraisal since 1973.The appraiser contributed to the writing of the IAAO’s standards on ratio studies.
Mr. O’Conner prepared a ratio study for January 1, 2007, and a statistical review of commercial sales occurring between 2004 and 2007, employing IAAO standards.He obtained the St. Louis County’s Assessment Division records of sales of commercial property from 2004 to 2009.He looked to properties selling in 2006 and 2007[6] with codes of P, U, V and X.O’Conner excluded sales of commercial properties that were coded as partial residential and/or agricultural.He included 239 sales in his study.
Mr. O’Conner compared the Assessor’s valuations with the sale price for the parcels and found an overall median ratio of 29.4%.When reviewed by property type, the median by type is:
Type |
% |
Median |
Office |
17.6 |
.307 |
Retail |
21.3 |
.271 |
Warehouse/Industrial |
35.1 |
.304 |
Miscellaneous Improved |
21 |
.279 |
Vacant Land |
5 |
.270 |
Michael Brooks, the acting assessor for St. Louis County[7], testified.He testified as to the process St. Louis County uses to verify sales.After the office receives a document such as a deed or certificate of value, the staff attempts to contact the parties to the sale and reviews terms of the sale to determine if the sale qualifies as a valid, arms length transaction.The review process includes amending the validity code as information is obtained.Mr. O’Conner was provided all sale verification information.
Mr. O’Conner reviewed the study performed by the Complainants’ expert.He was critical of the study due to the failure to verify the V coded sales.Mr. O’Conner testified that the Complainants used 261 V coded sales in their study or 83% of their sales.It is his opinion that 83% of sales coded V is high and “calls into question the reliability of the statistical inferences as to the average level of assessment of commercial class property in St. Louis County for 2007 tax year Complainants draw from their sales ratio study.”Mr. O’Conner further testified that IAAO emphasizes the importance of verifying the sales.
The County reviewed the 315 sales used by the Complainants’ expert.The County found that 177 sales were not valid sales.[8]At one time, the sales had been coded V (166), 1 (4), R (4), X (2) and Null (1).As the county reviewed V sales, the county changed the sales code to reflect the conditions of the sales which included conditions that would exclude the sales from sales studies.Failing to exclude the sales would call into question the reliability of the statistical inferences.
The County introduced the 2007 Commercial Ratio Study of St. Louis County completed by the PPRC and another 2007 study conducted by the State Tax Commission.The PPRC’s study found an overall median of 27.9%.The STC appraisal ratio study for 2007 found an overall median of 30.94%.
FINDINGS OF FACT
1.Jurisdiction over these appeals is proper.Complainants timely appealed to the State Tax Commission from the decision of the St. Louis County Board of Equalization.
2.The accuracy of valuation of property by assessors is a concern for assessors, taxing authorities, and taxpayers.Ratio studies evaluate appraisal performance.Dividing the appraised value by the market value forms the ratios.Market values can be represented in ratio studies by “sales prices that have been confirmed, screened and adjusted as necessary.”[9]
3.St. Louis County requires certificates of value to be filed on sales of real property.The certificate of value form asks the parties involved in a real property transaction questions to assist the reviewer in determining if the sale was an arm’s length transaction.The filer of the certificate of value certifies under penalty of law that the information contained therein is true and correct.
4.Certificates of value are indicators of valid sales and useful documents for ratio studies.
5.Sales studies rely on accurate information for sales of parcels.Verification of sales information, including information on a certificate of value form, should be conducted.“Sales data should be routinely confirmed or verified by contacting buyers, sellers, or other knowledgeable participants in the transaction.”[10]
6.Both the Respondent’s appraiser and the Complainants’ consultant are experts in the preparation of sales ratio studies.Complainants’ expert did not engage in the extensive verification of sales that Respondent pursued.
7.The State Tax Commission finds that the finds that median level of assessment for commercial property for the 2007 assessment cycle was 29.4%.
CONCLUSIONS OF LAW AND DECISION
Jurisdiction
The Commission has jurisdiction to hear this appeal and correct any assessment which is shown to be unlawful, unfair, arbitrary or capricious.The hearing officer shall issue a decision and order affirming, modifying or reversing the determination of the board of equalization, and correcting any assessment which is unlawful, unfair, improper, arbitrary, or capricious.[11]
Official and Judicial Notice
Agencies shall take official notice of all matters of which the courts take judicial notice.[12]
Courts will take judicial notice of their own records in the same cases.[13]In addition, courts may take judicial notice of records in earlier cases when justice requires[14] or when it is necessary for a full understanding of the instant appeal.[15] Courts may take judicial notice of their own records in prior proceedings involving the same parties and basically the same facts.[16]
Weight to be Given Evidence
The Commission is not bound by any single formula, rule or method, but is free to consider all pertinent facts and estimates and give them such weight as reasonably they may be deemed entitled.The relative weight to be accorded any relevant factor in a particular case is for the Commission to decide.[17]
Opinion Testimony by Experts
If specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert on that subject, by knowledge, skill, experience, training, or education, may testify thereto.
The facts or data upon which an expert bases an opinion or inference may be those perceived by or made known to the expert at or before the hearing and must be of a type reasonably relied upon by experts in the field in forming opinions or inferences upon the subject and must be otherwise reliable, the facts or data need not be admissible in evidence.[18]
The Commission as the trier of fact may consider the testimony of an expert witness and give it as much weight and credit as they may deem it entitled to when viewed in connection with all other circumstances.The Commission is not bound by the opinions of experts, but may believe all or none of the expert’s testimony and accept it in part or reject it in part.[19]
Complainants’ Burden of Proof
The taxpayer is the moving party seeking affirmative relief, therefore, the taxpayer bears the burden of proving the vital elements of the case, i.e., the assessment was “unlawful, unfair, improper, arbitrary or capricious,” by substantial and persuasive evidence[20]
Substantial evidence can be defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.[21]Persuasive evidence is that evidence which has sufficient weight and probative value to convince the trier of fact.The persuasiveness of evidence does not depend on the quantity or amount thereof but on its effect in inducing belief.[22]
The burden is on the taxpayer to prove discrimination.The evidence of discrimination must be competent and persuasive.If the evidence is not competent and persuasive, the presumption of validity remains with the assessor.[23]It is the burden of the taxpayer to establish intentional discrimination or an assessment so grossly excessive as to be entirely inconsistent with an honest exercise of judgment.[24]
In order to obtain a reduction in assessed value based upon discrimination, the Complainants must (1) prove the true value in money of their property on January 1, 2007; and (2) show an intentional plan of discrimination by the assessing officials resulting in an assessment of that property at a greater percentage of value than other property, generally, within the same class within the same taxing jurisdiction or show that the level of an assessment is so grossly excessive as to be inconsistent with an honest exercise of judgment. [25]
The only issue before the State Tax Commission at this time is the determination of the median level of assessment of commercial property located in St. Louis in 2007.The Tax Commission will hear evidence as to the valuation of individual parcels and whether those individual parcels suffer from discrimination at a later date.
Standards on Ratio Studies
The IAAO is an international organization for assessing professionals providing education, and research in property appraisal, assessment administration, and property tax policy.[26]All experts testifying at this hearing tout their association with the organization and cite IAAO as an authority for ratio studies.
The IAAO issued a Standard on Ratio Studies.“Assessors, appeal boards, taxpayers, and taxing authorities can use ratio studies to evaluate the fairness of funding distributions, the merits of class action claims, or the degree of discrimination.”[27]A ratio study is an effective tool for evaluation only if the proper steps are taken.There are seven steps involved: (1) define the purpose, scope and objectives; (2) design; (3) stratification; (4) collection and preparation of market data; (5) matching of appraisal and market data; (6) statistical analysis; and (7) evaluation and use of the results.The focus of this decision is on step (4) – the collection and preparation of market data.“The findings of a ratio study can only be as accurate as the data used in the study.”[28]
“The reliability of a ratio study depends in part on how well the sales used in the study reflect market values.”[29]There are numerous sources of sales data including deeds and real estate transfer affidavits, also known as certificates of value.“The usefulness of sales directly related to the completeness and accuracy of the data.Sales data should be routinely confirmed or verified by contacting buyers, sellers or other knowledgeable participants.”[30]The screening process objectives are to ensure (1) sales prices reflect only the market value of the real property transferred, (2) that sales occurred only during the period of analysis are used and (3) sales are excluded if good cause.[31]
DECISION
Sales Studies and Certificates of Value
Complainants presented a sales ratio study based on certificates of value filed in St. Louis County.Certificates of value, although a starting point for sales studies, do not necessarily provide accurate market information for the studies.[32]Independent review of sales and confirmation or verification of information is a necessary step.Neither the Complainants’ expert, nor his assistants, verified or confirmed the sales data.Without verification or confirmation of the data, the ratio study is suspect and therefore not conclusive or persuasive.
Respondent did verify and confirm sales data.Respondent’s study was performed in compliance with IAAO standards. The State Tax Commission finds that the finds that median level of assessment for commercial property for the 2007 assessment cycle was 29.4%.
SO ORDERED April 29, 2011.
STATE TAX COMMISSION OF MISSOURI
_____________________________________
Maureen Monaghan
Hearing Officer
Certificate of Service
I hereby certify that a copy of the foregoing has been mailed postage prepaid on this 29thday of April, 2011, to:Thomas Campbell, 101 S Hanley, Suite 1600, St. Louis, MO63105 Attorney for Complainant; Edward Corrigan, Associate County Counselor, County Government Center, 41 South Central Avenue, Clayton, MO 63105, Attorney for Respondent; Jake Zimmerman, Assessor, County Government Center, 41 South Central Avenue, Clayton, MO 63105; John Friganza, Collector, County Government Center, 41 South Central Avenue, Clayton, MO 63105.
___________________________
Barbara Heller
Legal Coordinator
List of Appeals
07-10657 |
Chez Paree Partners |
07-10658 |
Chez Paree Partners |
07-10659 |
Chez Paree Partners |
07-10660 |
Chez Paree Partners |
07-10661 |
James West Family Ltd. Partnership |
07-10662 |
West Five Ltd. McKee Realty |
07-10663 |
Chesterfield Hilltown, Inc. |
07-10664 |
Chesterfield MTBB |
07-10665 |
Chesterfield Hilltown, Inc. |
07-10666 |
Chesterfield Center Corporation |
07-10667 |
Chesterfield Payne Corp. |
07-10668 |
Chesterfield Northeast |
07-10669 |
Four Hundred Chesterfield Center, Inc. |
07-10670 |
Chesterfield Center Corporation |
07-10671 |
Chesterfield Center Corp. |
07-10672 |
Sunnen Products Company |
07-10673 |
Sunquad Corporation |
07-10674 |
Sunnen Products |
07-10675 |
Sunnen Products Company |
07-10676 |
Sunnen Products Company |
07-10677 |
Sunnen Products Company |
07-10678 |
Sunnen Products Company |
07-10679 |
Stocker Hausmann Foods |
07-10680 |
Joseph Haas Investment |
07-10681 |
Mid America Financial Corporation |
07-10682 |
Commerce Bank National Association |
07-10683 |
Commerce Bank of St. Louis |
07-10684 |
Commerce Bank of St. Louis County |
07-10685 |
Commerce Bank of Fenton |
07-10686 |
Commerce Bank of Florissant |
07-10687 |
Commerce Bank National Association |
07-10688 |
Security Bank of Manchester |
07-10689 |
Centennial Bank |
07-10690 |
Centennial Bank |
07-10691 |
Commerce Bank |
07-10692 |
Commerce Bank |
07-10693 |
Commerce Bank |
07-10694 |
Envirotech Pumpsystems |
07-10695 |
JBR Realty Company |
07-10696 |
Porta Fab Corporation |
07-10697 |
Hunter Engineering Company |
07-10698 |
Eighteen Investments, Inc. |
07-10699 |
Eighteen Investments, Inc. |
07-10700 |
Bell Scott LLC |
07-10701 |
Bell Scott LLC |
07-10702 |
Hackberry LLC |
07-10703 |
Eighteen Investments, Inc. |
07-10704 |
Eighteen Investments, Inc. |
07-10705 |
Unigroup, Inc. |
07-10706 |
Waterford Associates |
07-10707 |
Waterford Associates |
07-10708 |
RGB Construction Company |
07-10709 |
Commercial Bank of Westport |
07-10710 |
First Industrial |
07-10711 |
First Industrial |
07-10712 |
800 South Fillmore LLC |
07-10713 |
Rhomberg Realty, Inc. |
07-10714 |
Woodfield Properties, Inc. |
07-10715 |
Woodfield Properties, Inc. |
07-10716 |
Kennelwood Village, Inc. |
07-10717 |
Crest Development |
07-10718 |
Boegeman, Harry M. |
07-10719 |
Crest Development |
07-10720 |
Waycliffe Development |
07-10721 |
Boegeman H M Realty |
07-10722 |
H M Bogeman Realty |
07-10723 |
KWJ Properties, Inc. |
07-10724 |
Fredman Brothers Furniture |
07-10725 |
Southwest Bank |
07-10726 |
Southwest Bank |
07-10727 |
Southwest Bank |
07-10728 |
Missouri State Bank & Trust |
07-10729 |
Forty West Partners |
07-10730 |
Arsenal Credit Union |
07-10731 |
Burgundy Arrow LLC |
07-10732 |
Agatha Bloompetal Enterprises |
07-10733 |
Agatha Bloompetal Enterprises |
07-10734 |
Lin Ferry Investment Group |
07-10735 |
RS Property Investments |
07-10736 |
Opus Seven LLC |
07-10737 |
Elbridge Payne LLC |
07-10738 |
BCTN Holdings, Inc. |
07-10739 |
BCTN Holdings, Inc. |
07-10740 |
Wilhite Family Limited Partnership |
07-10741 |
Price, Howard B. |
07-10742 |
Smithkline Corp. |
07-10743 |
Smithkline Biosciences Laboratories |
07-10744 |
BSW Investors II LLC |
07-10745 |
2033 Concourse Limited Partnership |
07-10746 |
MDC Bonhomme LLC |
07-10748 |
National Wood Flooring Association |
07-10749 |
Graham Packaging Holdings |
07-10750 |
Baldor Electric |
07-10751 |
Baldor Electric |
07-10752 |
Milton Partnership |
07-10753 |
Wagner, Rita M. |
07-10754 |
Cleveland, John & Nancy |
07-10755 |
West N B Real Estate, Inc. |
07-10756 |
United States Tape & Label Corporation |
07-10757 |
First National Bank of St. Louis |
07-10758 |
First National Bank of St. Louis County |
07-10759 |
Rudder Group LLC |
07-10760 |
Zeigler Enterprises, Inc. |
07-10761 |
Zigs LLC |
07-10762 |
Zigs LLC |
07-10763 |
Ziegler Enterprises, Inc. |
07-10764 |
Ziegler Enterprises, Inc. |
07-10765 |
Temperato, Samuel J. |
07-10766 |
JB Management |
07-10767 |
JB Management |
07-10768 |
JP Management |
07-10769 |
Metro Alliance LLC |
07-10770 |
Premier Eyecare Services |
07-10771 |
Ouellette, Joseph & Catherine |
07-10772 |
TVT LLC |
07-10773 |
Manco LLC |
07-10774 |
San Properties LLC |
07-10777 |
Chesterfield 15450 LLC |
07-10778 |
Patandy LLC |
07-10779 |
DSMEFT LLC |
07-10780 |
CMC Real Estate Company |
07-10781 |
A H C Properties II |
07-10782 |
Metro Port, Inc. |
07-10783 |
Chesterfield Village, Inc. |
07-10784 |
Chesterfield Village, Inc. |
07-10785 |
Chesterfield Village, Inc. |
07-10786 |
Chesterfield Village, Inc. |
07-10787 |
Chesterfield Village, Inc. |
07-10788 |
Chesterfield Village, Inc. |
07-10789 |
Chesterfield Village, Inc. |
07-10790 |
Chesterfield Village, Inc. |
07-10791 |
Central Park Square, Inc. |
07-10792 |
Chesterfield Village, Inc. |
07-10793 |
Chesterfield Village, Inc. |
07-10794 |
Chesterfield Village, Inc. |
07-10795 |
Chesterfield Village, Inc. |
07-10796 |
Naples Milfield Venture |
07-10798 |
Midwest Petroleum Company |
07-10799 |
Levin, Bernard/Midwest Petroleum |
07-10801 |
Southpoint Plaza LLC |
07-10802 |
Lutheran Charities Association |
07-10803 |
Clayton Financial Corporation |
07-10804 |
Envirotech Pumpsystems |
07-10805 |
PSAF Development Partners |
07-10806 |
Public Storage, Inc. |
07-10807 |
Public Storage, Inc. |
07-10808 |
PSAC Development Partners |
07-10809 |
Public Storage Properties VII, Inc. |
07-10810 |
Public Storage Properties VII |
07-10811 |
Public Storage Properties |
07-10812 |
Public Storage Institutional Fund III |
07-10813 |
Storage Equities |
07-10814 |
Storage Equities |
07-10815 |
Storage Equities |
07-10816 |
Diversified Storage Fund II |
07-10817 |
Diversified Storage Fund |
07-10818 |
PS Co-Investment |
07-10819 |
Storage Trust Properties |
07-10820 |
A Stockage Storage of St. Louis |
07-10821 |
St. Louis Budget Storage Associates |
07-10822 |
A Stockade Storage of St. Louis |
07-10823 |
Highland Mini Storage |
07-10824 |
Ferguson Storage |
07-10825 |
Storage Trust Properties |
07-10826 |
Ferguson Storage Associates |
07-10827 |
Ferguson Storage Associates |
07-10828 |
Ferguson Storage Associates |
07-10829 |
Ferguson Storage Associates |
07-10830 |
Storage Trust Properties |
07-10831 |
Storage Trust Properties |
07-10832 |
Public Storage, Inc. |
07-10833 |
Public Storage, Inc. |
07-10834 |
North County Realty |
07-10835 |
Kirchner Block & Brick |
07-10836 |
Bluth, Raymond & Carol |
07-10837 |
Legends Acquisition Company |
07-10838 |
SSM Health Care St. Louis |
07-10839 |
Phoenix Properties |
07-10840 |
Panattoni Properties |
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AAA Overland LLC |
07-10842 |
AAA Overland |
07-10843 |
Lipton Bellefontaine LLC |
07-10844 |
Lipton Brentwood |
07-10845 |
SSC Acquisitions, Inc. |
07-10846 |
SSC Acquisitions, Inc. |
07-10847 |
Agatha Bloompetal Enterprises |
07-10848 |
Independent Concrete Pipe |
07-10849 |
St. Louis County Water |
07-10850 |
St. Louis County Water |
07-10851 |
St. Louis County Water |
07-10852 |
St. Louis County Water |
07-10853 |
St. Louis County Water |
07-10854 |
St. Louis County Water |
07-10855 |
St. Louis County Water |
07-10856 |
St. Louis County Water |
07-10857 |
St. Louis County Water |
07-10858 |
St. Louis County Water |
07-10859 |
Musgrave, Scott & Marsha |
07-10860 |
St. Louis County Water |
07-10861 |
St. Louis County Water |
07-10862 |
St. Louis County Water |
07-10863 |
St. Louis County Water |
07-10864 |
St. Louis County Water |
07-10865 |
301 Sovereign Court Associates |
07-10866 |
French Gibbs Properties |
07-10867 |
Gundaker Commercial Group, Inc. |
07-10868 |
L J H Enterprise LLC |
07-10869 |
Colonial Bank |
07-10870 |
Origo Holdings LLC |
07-10871 |
Scientech Corp. |
07-10872 |
McNamee, Bernard & Anne |
07-10873 |
McNamee, Bernard |
07-10874 |
Just, Richard L. |
07-10875 |
Just, Richard |
07-10876 |
Matrick Development |
07-10877 |
Matrick Development |
07-10878 |
Long Road Investments |
07-10879 |
Long Road Investments |
07-10880 |
Long Road Investments |
07-10881 |
Gateway News Service |
07-10882 |
Gateway News Service |
07-10883 |
McRae, Jill |
07-10884 |
Weiss, Michael & Michele |
07-10885 |
Sheehan, Danny |
07-10886 |
Perth LLC |
07-10887 |
AEMG LLC |
07-10888 |
Chesterfield Mustang LLC |
07-10889 |
KSAPA LLC |
07-10890 |
KSAPA LLC |
07-10891 |
Shaw, Thomas |
07-10892 |
Long Road Partnership |
07-10893 |
Express Enterprises LLC |
07-10894 |
Tamm Investment |
07-10895 |
MIJON IV |
07-10896 |
Des Peres Square Real Estate Holdings |
07-10897 |
CLR Industries, Inc. |
07-10898 |
Fusz, Eugene |
07-10899 |
Fusz, Eugene |
07-10900 |
Fusz, Eugene |
07-10901 |
Fusz, Paul |
07-10902 |
Lou Fusz Properties LLC |
07-10903 |
Fusz, Eugene |
07-10904 |
Fusz, Eugene |
07-10905 |
Fusz, Eugene |
07-10906 |
Fusz, Eugene |
07-10907 |
Ackerman, J.W. |
07-10908 |
Fusz, Eugene |
07-10909 |
Lincoln Investment |
07-10910 |
Lou Fusz Properties LLC |
07-10911 |
Lou Fusz Properties LLC |
07-10912 |
Comfort Printing and Stationery |
07-10913 |
Lou Fusz Properties LLC |
07-10914 |
Old Frontenac Square LLC |
07-10915 |
Saputo, Joseph & Madaline |
07-10916 |
Saputo, Joseph & Madaline |
07-10917 |
Potter Electric Signal Company |
07-10918 |
Potter Electric Signal Company |
07-10919 |
Olive Forty Corporation |
07-10920 |
Chesterfield 500 Corp. |
07-10921 |
Tubular Steel, Inc. |
07-10922 |
Tubular Steel, Inc. |
07-10923 |
Tubular Steel, Inc. |
07-10924 |
Tubular Steel, Inc. |
07-10925 |
Tubular Steel Industries |
07-10926 |
Tubular Steel Industries |
07-10927 |
Tubular Steel, Inc. |
07-10928 |
Jewish Federation of St. Louis |
07-10929 |
Jewish Federation of St. Louis |
07-10930 |
Storz Instrument Company |
07-10931 |
Midwest Petroleum Company |
07-10932 |
Midwest Petroleum |
07-10933 |
Froesel Oil Company |
07-10934 |
Heutel, Thomas & Michel |
07-10935 |
Sunset Hills Land Company |
07-10936 |
Sunset Hills Land Company |
07-10937 |
Sunset Auto Company |
07-10938 |
Meglio Investments |
07-10939 |
Meglio Investments |
07-10940 |
Lynntown Apartments |
07-10941 |
Lynntown Apartments |
07-10942 |
Commerce Bank of St. Louis |
07-10943 |
Clayton Financial Corporation |
07-10944 |
Commerce Bank of University City |
07-10945 |
Kovacik, Emil |
07-10946 |
Villa Manchester |
07-10947 |
Future III Partnership |
07-10948 |
Hiberian LLC |
07-10949 |
Deer Creek Real Estate |
07-10950 |
Deer Creek Real Estate |
07-10951 |
Deer Creek Real Estate |
07-10952 |
Commercial Bank |
07-10953 |
Twin Realty Company |
07-10954 |
Twin Realty |
07-10955 |
Joti Company, Inc. |
07-10956 |
Creve Coeur Medical Enterprises |
07-10957 |
First Industrial Mortgage |
07-10958 |
First Industrial Mortgage |
07-10959 |
First Industrial |
07-10960 |
First Industrial |
07-10961 |
First Industrial |
07-10962 |
Lipton Kenrick Associates |
07-10963 |
Lipton Kenrick Associates |
07-10964 |
Ronnies Plaza, Inc. |
07-10965 |
Chandler, Robert & Marilyn |
07-10966 |
8282 Forsyth LLC |
07-10967 |
8282 Forsyth LLC |
07-10968 |
Diamond Group LLC |
07-10969 |
Diamond Group LLC |
07-10970 |
Crest Development |
07-10971 |
Waycliffe Development |
07-10972 |
Crest Development |
07-10973 |
Boegeman, Harry M. |
07-10974 |
Corona Two Partnership |
07-10975 |
Jost Real Estate |
07-10976 |
J W E LLC |
07-10977 |
J W E LLC |
07-10978 |
Southwest Bank of St. Louis |
07-10979 |
Storage Banc of Florissant |
07-10980 |
AAA Fenton LLC |
07-10981 |
Lipton Realty, Inc. |
07-10982 |
Lipton Realty, Inc. |
07-10983 |
Johnny Investment Store |
07-10984 |
Johnny Investment Store |
07-10985 |
Johnny Investment Store |
07-10986 |
Johnny Investment Store |
07-10987 |
Johnny Investment Gem |
07-10988 |
Reinhardt, Joseph M. |
07-10989 |
Cars-DB2 LLC |
07-10990 |
Ken Behlmann Automotive Services, Inc. |
07-10991 |
Ken Behlmann Automotive Services |
07-10992 |
300 Hunter Realty LLC |
07-10993 |
Pawpsnon Fenton MO |
07-10994 |
Adriennes Goldmine |
07-10995 |
B & L Management LLC |
07-10996 |
Universe Corporation |
07-10997 |
MDC West Port LLC |
07-10998 |
Corley Printing Company |
07-10999 |
J & D Steinback LLC |
07-11000 |
J & D Steinback LLC |
07-11001 |
Gamemaster Athletic Company |
07-11002 |
Jade Crest Limited Partnership |
07-11003 |
Jade Crest Limited Partnership |
07-11004 |
Buhrman Brothers |
07-11005 |
Colonial Bank |
07-11006 |
Hankins Real Estate |
07-11007 |
Rudder Group LLC |
07-11008 |
Chrysler Realty Company |
07-11009 |
Jappa, Sheldon & Brenda |
07-11010 |
Naeda Services, Inc. |
07-11011 |
P & L Holdings LLC |
07-11012 |
Becker Enterprises LLC |
07-11013 |
Midcounty Realty LLC |
07-11014 |
Williams, R. Lee |
07-11015 |
Red Lobster Inns |
07-11016 |
Red Lobster Inns |
07-11017 |
Mid Rivers Plaza LLC |
07-11018 |
Mattingly, John & Shirley |
07-11019 |
CCM Real Estate |
07-11020 |
CMC Real Estate |
07-11021 |
CMC Real Estate |
07-11022 |
Kings Landing LLC |
07-11023 |
JMZ LI Real LLC |
07-11024 |
Samuels, Philip |
07-11025 |
Gerst, James & Valerie |
07-11026 |
Sansone, Zeke J. |
07-11027 |
Sansone, Zachary & Lynaner |
07-11028 |
Cooper Bussmann, Inc. |
07-11029 |
Cooper Bussmann, Inc. |
07-11030 |
Cooper Bussmann, Inc. |
07-11031 |
Cooper Bussmann, Inc. |
07-11032 |
Carboline Co. |
07-11033 |
Carboline Company |
07-11034 |
Carboline Co. |
07-11035 |
Carboline Company |
07-11036 |
Carboline Company |
07-11037 |
Consolidated Flavor Corporation |
07-11038 |
Fusz, Paul |
07-11039 |
Gold Dust LLC |
07-11040 |
James O. West Family Ltd. Partnership |
07-11041 |
Quick Point, Inc. |
07-11042 |
Quick Point Pencil |
07-11043 |
Chesterfield 1400, Inc. |
07-11044 |
Chesterfield Ridge Center |
07-11045 |
Harrington, Martin E. |
07-11046 |
Harrington, Martin E. |
07-11047 |
Industrial Dev. Auth. St. Louis County |
07-11048 |
Sherman, Ralph C. |
07-11049 |
Sherman, Ralph C. |
07-11050 |
Wherry, George & Barbara |
07-11051 |
Saco Auto Limited Partnership |
07-11052 |
D & D Distributors |
07-11053 |
D & D Distributors |
07-11054 |
J.D. Streett & Company |
07-11055 |
Maritz, Inc. |
07-11056 |
Maritz, Inc. |
07-11057 |
Maritz Corp. |
07-11058 |
Maritz Corp. |
07-11059 |
Maritz, Inc. |
07-11060 |
Sunset Auto Company |
07-11061 |
Meglio Investments |
07-11062 |
Koller Craft Plastic Products, Inc. |
07-11063 |
County National Realty |
07-11064 |
Fenton Properties, Inc. |
07-11065 |
Ford Steel Company |
07-11066 |
Hooverton |
07-11067 |
Ford Steel Company |
07-11068 |
Two Thousand One Hanley Center |
07-11069 |
Manchester Center I |
07-11070 |
Future 44 Company |
07-11071 |
Peter Pan LLC |
07-11072 |
American Communities II |
07-11073 |
American Communities II |
07-11074 |
Henges, Jay G. |
07-11075 |
Hunter Engineering |
07-11076 |
Hunter Engineering Company |
07-11077 |
Hunter Engineering |
07-11078 |
Hunter Engineering |
07-11079 |
Hunter Engineering |
07-11080 |
Latas, Michael |
07-11081 |
Fru Con Construction |
07-11082 |
McCarthy Brothers Company |
07-11083 |
Unigroup, Inc. |
07-11084 |
Vanliner Insurance Company |
07-11085 |
Layne Wester Company |
07-11087 |
Marchant Lumber Company |
07-11088 |
R G B Construction |
07-11089 |
Castillon, Donald & Carol |
07-11090 |
Rondal Investments |
07-11091 |
Kirchner Industries |
07-11092 |
Kirchner Industries |
07-11093 |
Vee-Jay Cement Contracting |
07-11094 |
Vee Jay Cement Contracting |
07-11095 |
Vee-Jay Cement Contracting |
07-11096 |
BKP Associates Best Steak House |
07-11097 |
First Industrial |
07-11098 |
First Industrial |
07-11099 |
First Industrial |
07-11100 |
Medventures Property Management |
07-11101 |
St. Joseph’s Hospital of Kirkwood |
07-11102 |
SSM Health Care St. Louis |
07-11103 |
BMT Holdings, Inc. |
07-11104 |
Krueger Properties LLC |
07-11105 |
E & M Canada LLC |
07-11106 |
Commerce Bank |
07-11107 |
Buckeye International, Inc. |
07-11108 |
Phoenix International Freight Services |
07-11109 |
Novus Webster LLC |
07-11110 |
211 West Lockwood LLC |
07-11112 |
French-Gerleman Electric Company |
07-11113 |
French Gerleman Electric |
07-11114 |
Patron, David & Linda |
07-11115 |
Jost Real Estate |
07-11116 |
Gateway Frontier Properties |
07-11117 |
Realty Associates Fund VII |
07-11118 |
Realty Associates |
07-11119 |
Realty Associates Fund V |
07-11120 |
Realty Associates Fund V |
07-11121 |
Realty Associates |
07-11122 |
Realty Associates Fund VII |
07-11123 |
Realty Associates Fund VII |
07-11124 |
Realty Associates Fund VII |
07-11125 |
Realty Associates Fund VII |
07-11126 |
Realty Associates Fund VI |
07-11127 |
Realty Associates Fund VII |
07-11128 |
Realty Associates Fund VII |
07-11129 |
Realty Associates Fund VIII |
07-11130 |
Realty Associates Fund VII |
07-11131 |
Realty Associates Fund VIII |
07-11132 |
Realty Associates Fund VII |
07-11133 |
Realty Associates Fund VIII |
07-11134 |
Reinhardt, Joseph M. |
07-11135 |
Dynamic Realty, Inc. |
07-11136 |
Ree Partnership LLC |
07-11137 |
Universal Sewing Supply |
07-11138 |
Universal Sewing Supply |
07-11139 |
Universal Sewing Supply |
07-11140 |
Universal Sewing Supply |
07-11141 |
Universal Sewing Supply |
07-11142 |
Wyne, William |
07-11143 |
Meyer, Robert & Denise |
07-11144 |
Mattis, Stephen & Mary |
07-11145 |
Padberg, Virginia |
07-11146 |
Padberg, Virginia |
07-11147 |
Gravois Development Partnership |
07-11148 |
Hoffman Industries LLC |
07-11149 |
Local Union No. 136 |
07-11150 |
Frost Electric Supply |
07-11151 |
Aback Realty |
07-11152 |
Kessler Page Development |
07-11153 |
S CB T LLC |
07-11154 |
Metro Court LLC |
07-11155 |
MDC Rider Trail LLC |
07-11156 |
RI Spirit Trade Center LLC |
07-11157 |
Stokes Realty LLC |
07-11158 |
MDC Hollenberg LLC |
07-11159 |
Airport Road LLC |
07-11160 |
KMOV-TV, Inc. |
07-11161 |
KMOV-TV, Inc. |
07-11162 |
KMOV-TV, Inc. |
07-11163 |
KMOV-TV, Inc. |
07-11164 |
Heyde Key Properties |
07-11165 |
Heyde Key Properties |
07-11166 |
Heyde Key Properties |
07-11167 |
Heyde Key Properties |
07-11168 |
Reichhold, Inc. |
07-11169 |
Campbell Taggart, Inc. |
07-11170 |
Campbell Taggart, Inc. |
07-11172 |
Cuccio Holdings LLC |
07-11173 |
RYA LLC |
07-11174 |
Choi Chi Woong |
07-11175 |
Stag #1 LLC |
07-11176 |
Rothman, Betty Jane & Milton |
07-11177 |
Alliant Foodservice, Inc. |
07-11178 |
Golterman Holding LLC |
07-11179 |
CRP Holdings |
07-11180 |
CRP Holdings |
07-11181 |
Smith & Newby Berkeley |
07-11182 |
Gundaker Commercial Group, Inc. |
07-11183 |
GHH Investments LLC |
07-11184 |
Woltman, Richard M. |
07-11185 |
Matrix Group, Inc. |
07-11187 |
Hennessey Dole Company |
07-11188 |
Professional Investment Partnership |
07-11189 |
1100 Research LLC |
07-11190 |
BLF LLC |
07-11191 |
JGDD Manchester LLC |
07-11192 |
Colonnade Gardner LLC |
07-11193 |
JB Management |
07-11194 |
JB Management |
07-11195 |
1750 South Hanley Road |
07-11196 |
4156 Shoreline Properties |
07-11197 |
Shoreline Court Investors LLC |
07-11198 |
Sams Real Estate LLC |
07-11199 |
Lynn Stuart, Inc. |
07-11200 |
Rothermich, Larry & Patricia |
07-11201 |
Ariel Investment LLC |
07-11202 |
Camenzind Family Ltd. Partnership |
07-11203 |
JFO Enterprises |
07-11204 |
Kerls, Jack & Judith |
07-11205 |
Express Enterprises LLC |
07-11206 |
Phoenix Films, Inc. |
07-11207 |
DLD Enterprise LLC |
07-11208 |
Berkeley Properties, Inc. |
07-11209 |
Lewis, Harold C. |
07-11210 |
Manufacturers Supplies Company |
07-11211 |
Tallman Pardee LLC |
07-11233 |
B-V Slavik, Inc. |
07-11234 |
Junior Properties LLC |
07-11235 |
Henry Plumbing Supply |
07-11236 |
39 Worthington Ltd. Partnership |
07-11237 |
Hanley Crossings |
07-11238 |
Chesterfield Stemme II |
07-11239 |
Chesterfield Stemme |
07-11240 |
Chesterfield Stemme |
07-11241 |
Construction Investment Company |
07-11242 |
Commerce Bank National Association |
07-11243 |
Commerce Bank National Association |
07-11244 |
Commerce Bank National Association |
07-11245 |
Spanish Lake Bank & Trust |
07-11246 |
Caplaco Twenty-Three |
07-11247 |
Big Bend Bank |
07-11248 |
Villa Lighting Supply Company, Inc. |
07-11249 |
JBR Realty Company |
07-11250 |
Lemay Manor |
07-11251 |
Anacott Properties |
07-11252 |
Anacott Properties |
07-11253 |
Anacott Properties |
07-11254 |
Anacott Properties |
07-11255 |
McKnight Man II |
07-11256 |
McKnight Man I |
07-11257 |
Clayton Forum Partnership |
07-11258 |
Cancila Family Real Estate |
07-11259 |
Zeller Properties LLC |
07-11260 |
Muchisky, Thomas & Michi |
07-11261 |
Halls Ferry Cine LLC |
07-11262 |
Halls Ferry Cine LLC |
07-11263 |
Wehrenberg, Inc. |
07-11264 |
THF Chesterfield Four Development |
07-11265 |
Ronnies Plaza, Inc. |
07-11266 |
Boegeman Construction |
07-11267 |
Waycliffe Development |
07-11268 |
Pennzoil United, Inc. |
07-11269 |
Pennzoil Products Company |
07-11270 |
2501 Adie Investors LLC |
07-11271 |
Rhodes Development |
07-11272 |
THF Chesterfield Development |
07-11273 |
THF Chesterfield Development |
07-11274 |
Gravois Bluffs South |
07-11275 |
Wea Chesterfield LLC |
07-11276 |
THF Maplewood Outparcel Development |
07-11277 |
THF Maplewood Outparcel Development |
07-11278 |
Red Lobster Inns |
07-11280 |
A H C Properties |
07-11281 |
MBSS Commercial Properties LLC |
07-11282 |
Guild Building LLC |
07-11283 |
Lou Fusz Properties LLC |
07-11284 |
Fusz, Louis J. |
07-11285 |
Forshaw of St. Louis, Inc. |
07-11286 |
Lindway Realty Company |
07-11287 |
Forshaw of St. Louis, Inc. |
07-11288 |
Old Frontenac Square LLC |
07-11289 |
1977 Properties LLC |
07-11290 |
Hillyard Sales |
07-11291 |
Husker Properties LLC |
07-11292 |
J.D. Streett & Company |
07-11293 |
Maritz, Inc. |
07-11294 |
Maritz, Inc. |
07-11297 |
Maritz, Inc. |
07-11300 |
Hooverton LP |
07-11301 |
Kramer, John & Florence |
07-11302 |
Gerst Development |
07-11303 |
Carol House Furniture |
07-11304 |
Storz Instrument Company |
07-11305 |
Mason Olive Central Associates |
07-11306 |
Trend Manufacturing Company |
07-11307 |
Taymor Lemay Manor II |
07-11308 |
Cancila, Martin A. |
07-11309 |
Cancila, Anthony & Lisa |
07-11310 |
R G B Construction Company |
07-11311 |
B B C Corporation |
07-11312 |
Hanley Auto Body, Inc. |
07-11313 |
Four Seventy Seven North Lindbergh |
07-11317 |
Southtown Investments |
07-11318 |
Southtown Investments |
07-11319 |
Des Peres Cine LLC |
07-11320 |
Des Peres Property North |
07-11321 |
Des Peres Property South |
07-11322 |
Des Peres Cine LLC |
07-11323 |
Wehrenberg, Inc. |
07-11324 |
Wehrenberg, Inc. |
07-11325 |
Ronnies Plaza, Inc. |
07-11326 |
Kennelwood Villages, Inc. |
07-11327 |
Buckeye International, Inc. |
07-11328 |
Harrah’s Maryland Heights |
07-11329 |
HMH LLC |
07-11330 |
Harrah’s Maryland Heights |
07-11331 |
Harrah’s Maryland Heights |
07-11332 |
Morrow Jesse Cushman & Wakefield, Inc. |
07-11333 |
Leader Investment Company II LLC |
07-11334 |
Stivers, Edward M. Jr. |
07-11335 |
Johnny Londoff Chevrolet, Inc. |
07-11336 |
Sinclair, David & Patricia |
07-11337 |
Sinclair, Patricia |
07-11338 |
Sinclair, David & Patricia |
07-11339 |
Reliv International, Inc. |
07-11340 |
Reliv International |
07-11341 |
Kitchin, John & Carol |
07-11342 |
Claybon Company |
07-11343 |
Brown Shoe Company |
07-11344 |
Brown Group, Inc. |
07-11345 |
Graham Packaging Holdings |
07-11346 |
First Industrial |
07-11347 |
South Lindbergh Property |
07-11348 |
Liebe, Robert J. Jr. |
07-11349 |
Treecourt Holding LLC |
07-11350 |
Whitehawk Investment Company LLC |
07-11351 |
Evans, Roy & Suzanne |
07-11352 |
GHH Investments LLC |
07-11353 |
GHH Investments LLC |
07-11354 |
Surendra Supta LLC |
07-11355 |
Surendra K. Gupta LLC |
07-11356 |
Surendra K. Gupta LLC |
07-11357 |
Surendra Gupta LLC |
07-11358 |
Surendra Gupta LLC |
07-11359 |
Gupta Real Estate LLC |
07-11360 |
American Radiolabeled Chemicals, Inc. |
07-11361 |
Surendra Gupta LLC |
07-11362 |
H R Petroleum, Inc. |
07-11363 |
Cresam Properties LLC |
07-11364 |
P & L Holdings LLC |
07-11365 |
P & L Holdings LLC |
07-11366 |
Tripos Realty LLC |
07-11367 |
8500 Manchester LLC |
07-11368 |
Sevens St. Louis LLC |
07-11369 |
STL Craigshire 1940 LLC |
07-11370 |
Marcal Company LLC |
07-11371 |
M & S |
07-11372 |
Glendale Chrysler Jeep |
07-11373 |
Merlo, Shirley A. |
07-11374 |
Ram International, Inc. |
07-11375 |
Two Oaks Corp. |
07-11376 |
Blessing Investments LLC |
07-11377 |
Mijon V |
07-11378 |
Walters Properties LLC |
07-11379 |
Charbonier Manor |
07-11380 |
Lackland Plaza |
07-11381 |
Metro Partners LLC |
07-12427 |
Terra Rosa LLC |
07-12438 |
Sansone, Joseph C. |
[2] In a discrimination case, the property owner must present evidence as to whether there was an intentional plan to assess the property at a ratio greater than 32% or at a ratio grossly excessive to the average 2007 commercial assessment ratio.This portion of the case is only to decide the average 2007 commercial assessment ratio; one element of a discrimination claim.
[3] All Exhibits, except Exhibit C are maintained by the State Tax Commission.Exhibit C will be returned to Complainant to maintain.
[7] Mr. Brooks was the acting assessor at the time of the hearing.Mr. Zimmerman was elected as the Assessor of St. Louis County after the hearing date.
[13] State ex rel. Horton v. Bourke, 129 S.W.2d 866, 869 (1939); Barth v. Kansas City Elevated Railway Company, 44 S.W. 788, 781 (1898).
[14] Burton v. Moulder, 245 S.W.2d 844, 846 (Mo. 1952); Knorp v. Thompson, 175 S.W.2d 889, 894 (1943); Bushman v. Barlow, 15 S.W.2d 329, 332 (Mo. banc 1929)
[15] State ex rel St. Louis Public Service Company v. Public Service Commission, 291 S.W.2d 95, 97 (Mo. banc 1956).
[16] In re Murphy, 732 S.W.2d 895, 902 (Mo. banc 1987); State v. Gilmore, 681 S.W.2d 934, 940 (Mo. banc 1984); State v. Keeble, 399 S.W.2d 118, 122 (Mo. 1966).
[17] St. Louis County v. Security Bonhomme, Inc., 558 S.W.2d 655, 659 (Mo. banc 1977); St. Louis County v. STC, 515 S.W.2d 446, 450 (Mo. 1974); Chicago, Burlington & Quincy Railroad Company v. STC, 436 S.W.2d 650 (Mo. 1968).
[18] Section 490.065, RSMo; State Board of Registration for the Healing Arts v. McDonagh, 123 S.W.3d 146 (Mo. SC. 2004); Courtroom Handbook on Missouri Evidence, Wm. A. Schroeder, Sections 702-505, pp. 325-350; Wulfing v. Kansas City Southern Industries, Inc., 842 S.W.2d 133 (Mo. App. E.D. 1992).
[19] St. Louis County v. Boatmen’s Trust Co., 857 S.W.2d 453, 457 (Mo. App. E.D. 1993); Vincent by Vincent v. Johnson, 833 S.W.2d 859, 865 (Mo. 1992); Beardsley v. Beardsley, 819 S.W.2d 400, 403 (Mo. App. 1991); Curnow v. Sloan, 625 S.W.2d 605, 607 (Mo. banc 1981).
[20] See, Westwood Partnership v. Gogarty, 103 S.W.3d 152 (Mo. App. E.D. 2003); Daly v. P. D. George Co., 77 S.W.3d 645 (Mo. App. E.D. 2002); Reeves v. Snider, 115 S.W.3d 375 (Mo. App. S.D. 2003).Industrial Development Authority of Kansas City v. State Tax Commission of Missouri, 804 S.W.2d 387, 392 (Mo. App. 1991).
[23] Town & Country Racquet Club v. State Tax Commission of Missouri, 811 S.W.2d 403 (Mo. App. 1991).
[25] Savage v. State Tax Commission, 722 S.W.2d 72 (Mo. banc 1986); Westwood Partnership v. Gogarty, 103 S.W.3d 152 (Mo. App. E.D. 2003.)
[26] http://www.iaao.org/