Justice KNECHT delivered the opinion of the court:
In April 2008, taxpayer, KT Winneburg, LLC, purchased the real property in question—namely, approximately 88 tracts of land situated in Calhoun County—in bulk at a foreclosure sale. Subsequently, respondent, S. Brandi Fester, Calhoun County supervisor of assessments (Supervisor), changed the classification of the property from farmland to residential and reassessed it accordingly, resulting in an increase...
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