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This is an ad-valorem tax dispute involving 50 tracts of land owned by Georgia-Pacific Corporation in Talbott County. These tracts are classified by the State Revenue Department as woodlands and were appraised by the Talbott County Board of Tax Assessors at an average value of $561 per acre in 1998. Georgia-Pacific appealed these valuations without success to the Talbott County Board of Tax Assessors and Board of Equalization. The Board of Tax Assessors found the valuations to be in line with those of comparable properties.

In an appeal by Georgia-Pacific to the superior court, the case was tried before a jury. Georgia-Pacific sought to admit as evidence of comparable properties 24 privately-owned woodland tracts appraised by the Board of Tax Assessors at an average value of $371 per acre. At the commencement of trial, the court granted the Board’s motion in limine to exclude evidence concerning 19 of these 24 tracts on the ground that they are not comparable to Georgia-Pacific’s properties because they are classified as “bona fide conservation use property” under OCGA § 48-5-7.4. Georgia-Pacific appeals judgment on a jury verdict leaving the valuations of its tracts unchanged.

 
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