CSX Transportation, Inc. v. Georgia State Board of Equalization
CSX Transportation sued the Georgia State Board of Equalization under section 306 of the Railroad Revitalization and Regulatory Reform Act of 1976, challenging the Board's appraisal of its property at $8.2 billion. Section 306 requires, for purposes of levying a property tax, that the ratio of assessed value to true market value of railroad property not exceed by more than five percent the ratio of assessed value to true market value of all other commercial and industrial property in the same assessment jurisdiction.
The district court refused to consider an appraisal proffered by the Railroad that valued the property of the Railroad at $6 billion because the district court concluded that the appraisal was based on a valuation methodology different from the one used by the State. On appeal, the Railroad argues that the Act allows it to challenge the valuation methodology of a state. The Eleventh Circuit Court of Appeals rejected the Railroad's argument because the Act does not clearly state that railroads may challenge state valuation methodologies.
Question Presented:
Whether, under the federal statute prohibiting state tax discrimination against railroads, 49 U.S.C. § 11501(b)(1), a federal district court determining the “true market value” of railroad property must accept the valuation method chosen by the State.
