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4. Quantity and Size — See No. 2. S. Cost and Present Replacement Value — We used the State of Florida Life assignments, Index Tables and Depreciation schedules. We performed our Annual Market Research and compared the results to the state's tables.. We also considered the information presented in the prior year VAB hearings and where necessary, we make adjustments to our asset lives and tables. 6. Condition --See No. 2. 7. Income — The income approach is used to assess regulated utilities in conjunction with the book cost approach method to perform a unit approach to value. This is typically how this industry is assessed across the State of Florida; however, many choose the use of the cost approach alone because of the subjective elements of the income approach. Income is also being used with assets that are leased. In both situations, it is considered to be appropriate in the DOR's Manual of Instructions and supported by existing case law. 8. Net proceeds of sale — Since there were not any direct sales to use in the development of the assessments, or used in any of the methods or sources used to test or make comparisons to the assessments, no adjustments were warranted. We specifically look for the indicators that costs regarding the sale or purchase of equipment were included, in every return we process and every sales comp we use in our Market Research; Specialized industries and utilities purchase as going concerns are always sold owner to owner, no middle man or costs of sale have ever been recorded or cited, and when we have asked these companies they have only confirmed the fact that they do not apply in these cases. With general office and store personal property, these assets are used until there is little value left, so the idea that some would pay someone else to sell it for them is very unlikely: In most all cases, the assets are either thrown away or given away; in some cases, they are sold for pennies on the dollar to secondary resellers: In all of these cases, the action is not that of a commission being render for a service being provided, but rather that the asset is not worth spending any money on, even the cost of removal: Trade level is critical when considering the 8th criteria; It is in appropriate to apply a broker or auction fee that may be applicable at the secondary trade level, to a first trade level taxpayer who always buys new equipment; In the event an actual cost of sale occurred, it should be identified by the taxpayer and would be considered in our assessment: However, blanket application of a cost of sale, who no "relevant and credible" evidence exists that these costs have been incurred, or would be incurred in .a hypothetical sale, is a direct violation of Property Tax Oversight Bulletin 11-01." The PA reviews DOR's tables and then develops their own tables. The PA discussed the various lives used by DOR and � County. DOR's life expectancy guidelines are 10 years for laundry equipment. County uses an 8 year life. The 2016 Present Worth Tables for wave some adjustments. The PA discussed the market value composites based on the industries, studies from tax returns to obtain model numbers, year. of acquisition, cost and comparables for those items. A bar chart and grid of the comparables was presented to substantiate their adjustments. The PA also studies the Tax Return E - Files and downloads new or changed items to be tabulated. Based on the data, the PA applies more depreciation. Leasing companies, utilities and wholly exempt returns are excluded from the data reviewed. Data from businesses sold is also compared with regard to the old and new owners returns. They look at the individual breakdown of the life of the assets and effective age. The PA requested Ryan s tables used to develop their % good and weighted average age. This was not provided by Ryan. The PA contacted some of the dealers in Ryan's evidence. The dealer's original cost does not include a manufacturer's warranty and does not recall speaking with Ryan. Some of these assets are over 22 years of age. He stated that the Agent did not petition all of the accounts. An income approach is done for utility companies and can be used for leasing companies. Ryan did not do an income approach or provide the information to do so. F.S. Section 193.011 requires the PA to consider each of the 8 factors but does not require the PA to. apply or use any factor that is not probative of just value. Based on the above, the PA believes that they. have complied with the 8 factors of the statutes. Petitioner/Agent; The Agent restated the requirements for the presumption of correctness within F.S. She questioned the PA's use of the taxpayer's estimate of fair market value (FNM to establish a percentage as being credible evidence. The Agent also believes that using data from businesses sold is not relevant evidence. She asked the PA for the supporting data for his use of "x 2" in his calculation of effective average age. The PA -73-