Per Curiam.
The auditor did not file a notice of appeal, but in his brief as appellee he argues for reversal of the BTA's decision. Sua sponte, the court strikes the auditor's brief.
The gist of the BOE's first contention is that the rebuttable presumption that sale price reflects true value arises in a valuation case only after proof that that sale was an arm's-length sale. We disagree with the BOE's contention.
In prior decisions we...
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