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  5. 793 S.W.2d 490 (1990)
 

ABELN v. STATE TAX COM'N OF MISSOURI

No. 57575.

793 S.W.2d 490 (1990)

Raymond ABELN, et al., Appellants, v. The STATE TAX COMMISSION OF MISSOURI, et al., Respondents.

Missouri Court of Appeals, Eastern District, Division Three.

Motion for Rehearing and/or Transfer Denied July 26, 1990.

Application to Transfer Denied September 11, 1990.

Attorney(s) appearing for the Case

Jerome Wallach, St. Louis, for appellants.

Timothy M. Joyce, Warrenton, for respondents.

Motion for Rehearing and/or Transfer to Supreme Court Denied July 26, 1990.

GRIMM, Judge.

Appellant landowners dispute the tax assessment of several hundred lots in a lake development called Innsbrook Estates. The State Tax Commission found that landowners did not present substantial evidence to refute the county assessor's assessment. The circuit court affirmed.

On appeal, landowners contend they "presented substantial evidence of probative value...

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