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Finding of fact for petition number 2023-145 List of Property Appraiser's witnesses and exhibits: Jarrett Hovda, representing the Property Appraiser's Office, appeared by phone. The Property Appraiser's (PA's) evidence package consisted of 36 pages. The evidence included, a summary of the evidence to be submitted, a summary of details for the subject property, aerials of the subject and photos, a Costar summary of the recent sale of the subject and a project in Naples, mortgage recordings for both properties, an income approach, summary charts with rent comparables, operating expenses and occupancy rates, the floor plans with asking rents for most of the subject units, capitalization rate support from CoStar, 6 sales of apartment complexes presented in a chart and sales summary sheets, the property record cards for the subject and an article from Cushman & Wakefield regarding South Florida Multifamily 2023 Forecast. The above evidence was submitted in to Axia and was admitted in to evidence. List of Petitioner's witnesses and exhibits: Maksym Marchenko, with Property Tax Services, representing the property owner, appeared by phone. The petitioner submitted an evidence package that consisted of 48 pages. The evidence included a summary sheet of the evidence submitted, the property record information from Martin County, the TRIM notices, aerials and a photo of the subject, the DR -493 for Martin County, an income analysis proforma, Property Analytics from CoStar showing rents, vacancy, concessions for the subject and the submarket (data as of 1/16/2024), cap rate support from CoStar, a rent comparable analysis from Moody's Analytics (data as of 3/2023), Cost of Sale (COS) information from the FL DOR, various surveys and articles regarding overall rates, occupancy levels, expense rates, insurance, mortgage and equity rates from RERC, CoStar, RealtyRates, PwC and inhouse data. The evidence also included 17 pages of information from the 2023 VAB Training manual regarding the COS deduction, 78 pages from the Florida Department of Revenue regarding the 8th Criterion and the correct method of deducting cost of sale (COS) in income capitalization approach. The petitioner submitted 2 pages of rebuttal evidence showing a comparison of the income approach used by the petitioner and the PA. 1 -43-