OPINION
BARRON, Judge.
On March 15, 1988, Tatten Partners, L.P. (Tatten) filed an annual assessment appeal to the Board of Assessment Review of New Castle County (the Board), alleging that its property at 22 Delaware Avenue, Wilmington, Delaware (the property) was substantially overassessed. The County had originally assessed the value of the property at $39,762,600, in terms of July 1, 1983 values...
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