Property tax appeals are complex because the burden of proof is on the taxpayer to demonstrate that the assessment is incorrect, but once the taxpayer demonstrates the county’s assessment is incorrect, the burden then shifts to the county to demonstrate that the assessment should be at a certain level. Even though both sides have this shifting burden of proof, the tax court judge sits in judgment of the case and is supposed to exercise independent judgment, independent of both sides’ arguments, to determine what the actual fair market value of the property is. So it requires complex presentation of appraisals, opinions of property value, and then in the end, the tax court judge is free to accept or reject any of the evidence that’s given to her.