Thus, the title and legend suggest that the intention of the general meeting was to limit the revaluation of the property for two years, except under certain conditions after a decision on fmV was made on appeal by the County Equalization Board or the Supreme Court. The reason for such a change is that some county tax auditors in the name of the law and the state revenue commissioner, who must approve County Tax Digests each year, have reassessed the property upwards each year, even though the county`s tax appraisers compromise, settle or lose appeals against such an FMV before equalization committees or the Supreme Court. and the reviewers repeatedly reaffirmed this reassessment in subsequent years. This is the approach of re-evaluation by “salami slices”, one small slice at a time; This reduces the entire reassessment, although appraisers may lose most of what they re-evaluate in the call, receive a small reassessment each time, or sooner or later the owner will miss a deadline to file appeals or drop the fight without appeal. This approach is costly for the owner in terms of attorneys` fees, litigation costs, and time. Worse still, it appears to the owner as a hopeless and endless battle with the government to take more taxes than is due. Therefore, it is not surprising that the General Assembly intended to grant some relief to the owner after a tax complaint, regardless of the outcome. The clear and unambiguous wording of the amendment provides significant tax relief through repeated annual reassessments by reviewers if there has been an appeal made simply to increase revenues without the need for county commissioners, school board or local board to take any politically unpopular action to increase the mileage rate. The revaluation of the property in question requires a modification of these factors, which are specifically examined to see how the factors affect the FMV of the property in question as a condition precedent to the revaluation. In accordance with Article 48-5-299(c) of the OCGA, these factors are disclosed as follows: (1) additions to improved real property; (2) the deletion of improved immovable property; (3) the improvement of the property; and (4) “the emergence of other factors that could affect the current market value”. (Emphasis added.) Factors occurring before the two-year period are assumed to have already influenced fmV as determined by the Equalization Chamber or the Supreme Court on Appeal specifically for the assets in question and can only be redefined if error or fraud in such a revaluation is demonstrated. Therefore, in order to avoid unequal treatment of other property valuations after a territorial or county-wide reassessment, a reassessment will not address the specific factors, since the previous reassessment against which an appeal was brought has already determined the FMV of the property in question in the county. To interpret the legislative wording as allowing for a general reassessment for a period of two years, despite the specific prohibition on re-evaluation, without exception, would render the legislature`s amendment meaningless, as if it had never been adopted, and would lead to an absurd result.
Therefore, the general increase in FMV cannot be used as a catch factor for either the property in question or the surrounding property, unless there is one or more of the three factors mentioned above or other similar specific factors. Sirmans v. Sirmans, 222 Ga. 202, 204, 149 P.E.2d 101 (1966); see also Lamons v. Yarbrough, loc. cit. Paragraph (c) of OCGA § 48-5-299 was added by Ga.L.1994, p. 786, § 1. . . . .
