CSX TRANSPORTATION, INC. v. GEORGIA STATE BOARD OF EQUALIZATION et al.

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CSX TRANSPORTATION, INC. v. GEORGIA STATE
BOARD OF EQUALIZATION et al.
certiorari to the united states court of appeals for
the eleventh circuit
No. 06–1287. Argued November 5, 2007—Decided December 4, 2007
Under Georgia law, most commercial and industrial property is valued
locally by county boards for tax purposes, but public utilities such as
petitioner railroad (CSX) are initially valued by the State. In 2002,
respondent Georgia state board used a different combination of method
ologies than it had in 2001 to determine that the market value of CSX’s
in-state real property had increased 47 percent, resulting in a signifi
cantly higher ad valorem tax levy. CSX filed suit under the Railroad
Revitalization and Regulatory Reform Act of 1976 (4–R Act or Act),
which bars States from, inter alia, “[a]ssess[ing] rail transportation
property at a value that has a higher ratio to the [property’s] true mar
ket value . . . than the ratio” between the assessed and true market
values of other commercial and industrial property in the same taxing
jurisdiction, 49 U. S. C. § 11501(b)(1), and authorizes the federal district
court to enjoin the tax if the railroad ratio exceeds the ratio for other
property by at least five percent, § 11501(c). CSX alleged that Georgia
had grossly overestimated the market value of its in-state rail property
while accurately valuing other commercial and industrial property in
the State, so that CSX’s property was taxed at a ratio of assessed-to
market value considerably more than 5 percent greater than the same
ratio for the other in-state property. Ruling that Georgia had not dis
criminated against CSX in violation of the 4–R Act because the State
had used widely accepted valuation methods to arrive at its 2002 esti
mate of true market value, the District Court declared that the Act does
not allow a railroad to challenge a State’s chosen methodology if it
is rational and not motivated by discriminatory intent. The Eleventh
Circuit panel affirmed, reasoning that the Act does not clearly state
that railroads may challenge valuation methodologies, and that such a
clear statement was required in light of the intrusion on state taxing
prerogatives.
Held: The 4–R Act allows a railroad to attempt to show that state meth
ods for determining the value of railroad property result in a discrimina
tory determination of true market value. Pp. 16–22.
(a) The Act’s language is clear. States may not tax railroad property
at a ratio of assessed-to-true-market value higher than the ratio for

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10 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
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Syllabus
other commercial and industrial property in the same jurisdiction. To
apply the Act, district courts must calculate the true market value of
in-state railroad property. A court cannot undertake the comparison of
ratios the statute requires without that figure at hand, see Burlington
Northern R. Co. v. Oklahoma Tax Comm’n, 481 U. S. 454, 461, and the
determination of true market value may be affected by the State’s
choice of valuation methods. Georgia’s argument that valuation meth
odologies must be distinguished from their application, and that the Act
allows courts to question only the latter, is rejected. There is no dis
tinction between method and application in the Act’s language and no
passage limiting district court factfinding as the State proposes. Geor
gia’s position is untenable given the way market value is calculated.
Valuation is not a matter of mathematics, but an applied science, even a
craft. Most appraisers estimate market value by employing not one
methodology but a combination because no one approach is entirely ac
curate, at least in the absence of an established market for the type
of property at issue. The individual methods yield sometimes more,
sometimes less reliable results depending on the peculiar features of the
property evaluated. Given the extent to which the chosen methods can
affect the determination of value, preventing courts from scrutinizing
state valuation methodologies would render § 11501 a largely empty
command, forcing district courts to accept as “true” the market-value
estimate of the State, one of the parties to the litigation. States, in
turn, would be free to employ appraisal techniques that routinely over
estimate the market worth of railroad assets. By then levying taxes
based on those overestimates, States could implement the very discrimi
natory taxation Congress sought to eradicate. Courts would be power
less to stop them, and the Act would ultimately guarantee railroads
nothing more than mathematically accurate discriminatory taxation.
The State’s warning that allowing railroads to introduce their own
valuation estimates based on different methodologies will inevitably
lead to a futile clash of experts, which courts will have no reasonable
way to settle, is not compelling, given that Congress was not similarly
troubled. Rather, Congress directed courts to find true market value,
however elusive, making that value the objective benchmark for courts’
evaluation. Property valuation, though admittedly complex, is at bot
tom just “an issue of fact about possible market prices,” Suitum v. Tahoe
Regional Planning Agency, 520 U. S. 725, 741, an issue district courts
are used to addressing. In light of the statute’s directive making true
market value a factual question to be determined by the district court,
what Georgia really seeks is to limit the types of evidence courts may
consider as part of their factual inquiry. Had Congress intended to
impose such a limit, it could easily have included language insulating

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the State’s chosen methodologies from judicial scrutiny. It did not.
Pp. 16–19.
(b) The State argues that any interpretation of the Act allowing
courts to question state valuation methods ignores the background prin
ciples of federalism against which the statute was enacted. Even if
important state policy questions are intertwined with the selection of a
valuation methodology, however, Congress clearly permitted courts to
question such methodologies when it banned discriminatory assessment
ratios and made true market value a question to be litigated in federal
court. Department of Revenue of Ore. v. ACF Industries, Inc., 510
U. S. 332, 343–344, distinguished. The Court also disagrees with Geor
gia’s claim that the Court’s interpretation will destroy the States’ dis
cretion to choose their own valuation methodologies. A State may use
whatever method it likes, so long as the result is not discriminatory in
violation of the Act. Pp. 20–22.
472 F. 3d 1281, reversed.
Roberts, C. J., delivered the opinion for a unanimous Court.
Carter G. Phillips argued the cause for petitioner. With
him on the briefs were Stephen B. Kinnaird, Ileana M. Cio
banu, Matthew J. Warren, James W. McBride, Ellen M.
Fitzsimmons, David J. Bowling, and Peter J. Shudtz.
Douglas Hallward-Driemeier argued the cause for the
United States as amicus curiae in support of petitioner.
With him on the brief were Solicitor General Clement, As
sistant Attorney General Keisler, Deputy Solicitor General
Hungar, Anthony J. Steinmeyer, Robert D. Kamenshine, and
Ellen D. Hanson.
Warren R. Calvert, Senior Assistant Attorney General of
Georgia, argued the cause for respondents. With him on the
brief were Thurbert E. Baker, Attorney General, R. O. Lerer,
Deputy Attorney General, Peter J. Crossett, and John D.
Cook.*
*Briefs of amici curiae urging reversal were filed for the Association
of American Railroads by Betty Jo Christian, Timothy M. Walsh, and
Michael A. Vatis; for the Council on State Taxation by Stephen P. Kranz
and Douglas L. Lindholm; and for the Tax Foundation by Brian E. Bailey.
Sheldon H. Laskin filed a brief for the Multistate Tax Commission as
amicus curiae.

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12 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
Chief Justice Roberts delivered the opinion of the
Court.
The Railroad Revitalization and Regulatory Reform Act
of 1976 prohibits States from discriminating against rail
roads by taxing railroad property more heavily than other
commercial property in the State. Two decades ago, we
held that this statute permits an aggrieved railroad to chal
lenge a State’s valuation of its property for tax purposes.
Burlington Northern R. Co. v. Oklahoma Tax Comm’n, 481
U. S. 454, 462 (1987). Because the railroad in that case chal
lenged only the State’s application of its valuation methods,
we expressly reserved the question whether a railroad may
challenge the State’s methods themselves. We answer that
question today, and hold that railroads may challenge state
methods for determining the value of railroad property, as
well as how those methods are applied. The statute pro
vides for nothing less.
I
Congress enacted the Railroad Revitalization and Regula
tory Reform Act in 1976. 90 Stat. 31.1 Called the “4–R
Act” for brevity, the law aimed to halt the economic decline
of the rail industry by, among other means, barring “discrim
inatory state taxation of railroad property.” Burlington
Northern, supra, at 457; see also Department of Revenue of
Ore. v. ACF Industries, Inc., 510 U. S. 332, 336 (1994). The
4–R Act prohibits four separate forms of discriminatory
state taxation of railroads.2 Only the first is at issue here:
1 The portion of the Act that concerns us here, § 306, was originally codi
fied at 49 U. S. C. § 26c (1976 ed.). In 1978, Congress recodified it at 49
U. S. C. § 11503 (1976 ed., Supp. II). Congress recodified it again in 1995,
without substantive change, this time as § 11501. For convenience, all
references to the statute are to the text of § 11501.
2 Section 11501 reads, in relevant part:
“(b) The following acts unreasonably burden and discriminate against
interstate commerce, and a State, subdivision of a State, or authority act
ing for a State or subdivision of a State may not do any of them:

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States, the Act provides, may not “[a]ssess rail transporta
tion property at a value that has a higher ratio to the [prop
erty’s] true market value . . . than the ratio” between the
assessed and true market values of other commercial and
industrial property in the same taxing jurisdiction. 49
U. S. C. § 11501(b)(1). If the railroad ratio exceeds the ratio
for other property by at least five percent, the district court
may enjoin the tax. § 11501(c).3
“(1) Assess rail transportation property at a value that has a higher
ratio to the true market value of the rail transportation property than the
ratio that the assessed value of other commercial and industrial property
in the same assessment jurisdiction has to the true market value of the
other commercial and industrial property.
“(2) Levy or collect a tax on an assessment that may not be made under
paragraph (1) of this subsection.
“(3) Levy or collect an ad valorem property tax on rail transportation
property at a tax rate that exceeds the tax rate applicable to commercial
and industrial property in the same assessment jurisdiction.
“(4) Impose another tax that discriminates against a rail carrier provid
ing transportation subject to the jurisdiction of the Board under this
part.”
3 Section 11501(c) provides:
“Notwithstanding section 1341 of title 28 and without regard to the
amount in controversy or citizenship of the parties, a district court of the
United States has jurisdiction, concurrent with other jurisdiction of courts
of the United States and the States, to prevent a violation of subsection
(b) of this section. Relief may be granted under this subsection only if
the ratio of assessed value to true market value of rail transportation
property exceeds by at least 5 percent the ratio of assessed value to true
market value of other commercial and industrial property in the same
assessment jurisdiction. The burden of proof in determining assessed
value and true market value is governed by State law. If the ratio of the
assessed value of other commercial and industrial property in the assess
ment jurisdiction to the true market value of all other commercial and
industrial property cannot be determined to the satisfaction of the district
court through the random-sampling method known as a sales assessment
ratio study (to be carried out under statistical principles applicable to such
a study), the court shall find, as a violation of this section—
“(1) an assessment of the rail transportation property at a value that
has a higher ratio to the true market value of the rail transportation prop

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14 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
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Opinion of the Court
Petitioner CSX Transportation, Inc., is a freight rail car
rier with multiple routes across the State of Georgia. As a
consequence, it is subject to Georgia’s ad valorem tax on real
property. Under Georgia law, most commercial and indus
trial property is valued locally by county boards. Public
utilities such as railroads, however, are initially valued by
the State, which then certifies the proposed valuations to the
county boards for adoption or alteration. In 2001, Georgia’s
State Board of Equalization, a respondent here, put CSX’s
ad valorem tax liability at $4.6 million. A year later, the
State’s appraiser used a different combination of methodolo
gies to determine the market value of CSX’s in-state prop
erty.4 The result was a significantly higher tax levy. The
State estimated the railroad’s 2002 market value at approxi
mately $7.8 billion, 472 F. 3d 1281, 1285 (CA11 2006), a
47 percent increase over the previous year. That brought
the assessed value of CSX’s Georgia property to $514.9 mil
lion, for a final property tax bill of $6.5 million. Brief for
Petitioner 15.
CSX filed suit in the United States District Court for the
Northern District of Georgia, contending that the State’s
2002 tax assessment violated the 4–R Act. The railroad al
leged that Georgia had grossly overestimated the market
erty than the assessed value of all other property subject to a property
tax levy in the assessment jurisdiction has to the true market value of all
other commercial and industrial property; and
“(2) the collection of an ad valorem property tax on the rail transporta
tion property at a tax rate that exceeds the tax ratio rate applicable to
taxable property in the taxing district.”
4 Georgia assesses public utilities using the “unit rule.” Under this
rule, “an appraiser first determines the value of all assets of an entity,
regardless of location,” then multiplies “by the percentage of the entity
located within [the State] to determine what portion of the value of the
company should be allocated to the state.” 472 F. 3d 1281, 1283 (CA11
2006). The parties agree the unit rule is the appropriate rule for valuing
CSX’s property. There are, however, numerous methods available to
value property under the unit rule, and many of these methods themselves
have multiple variations. See id., at 1284.

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value of its in-state property while accurately valuing other
commercial and industrial property in the State. The re
sult, according to CSX, was that its rail property was taxed
at a ratio of assessed-to-market value considerably more
than five percent greater than the same ratio for the other
property in the State.
To make its case, CSX submitted the testimony of its own
expert appraiser, who relied on a combination of valuation
methods different from those used by the appraiser for Geor
gia. The CSX appraiser calculated the 2002 market value
of the railroad’s property to be $6 billion, not the $7.8 billion
figure used by the State. 472 F. 3d, at 1285–1286. CSX
maintained that the state appraiser’s valuation methodolo
gies were flawed, and urged the District Court to accept the
market value estimated by its expert as more accurate.
The District Court refused to do so. Following a bench
trial, the court ruled Georgia had not discriminated against
CSX in violation of the 4–R Act because the State had used
widely accepted valuation methods to arrive at its estimate
of true market value. 448 F. Supp. 2d 1330, 1341 (ND Ga.
2005). In the judgment of the District Court, the Act “does
not generally allow a railroad to challenge the state’s chosen
methodology,” as long as the State’s methods are rational
and not motivated by discriminatory intent. Ibid.
A divided panel of the Court of Appeals for the Eleventh
Circuit affirmed. 472 F. 3d 1281. The majority reasoned
that the “text of the Act does not clearly state that railroads
may challenge valuation methodologies,” and that such a
clear statement was required in light of the intrusion on
state taxing prerogatives. Id., at 1289. Judge Fay dis
sented. Id., at 1292. Recognizing the division on this ques
tion among the Circuits, compare Consolidated Rail Corpo
ration v. Hyde Park, 47 F. 3d 473, 481–482 (CA2 1995) (a
railroad may challenge a State’s valuation methodology), and
Burlington Northern R. Co. v. Department of Revenue of
Wash., 23 F. 3d 239, 240–241 (CA9 1994) (same), with Chesa

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peake Western R. Co. v. Forst, 938 F. 2d 528, 531 (CA4 1991)
(a railroad may not challenge a State’s valuation methodol
ogy), and 472 F. 3d, at 1289 (case below), we granted certio
rari, 550 U. S. 968 (2007), and now reverse.
II
“[T]he language of § 1150[1] plainly declares the congres
sional purpose.” Burlington Northern, 481 U. S., at 461.
States may not tax railroad property at a ratio of assessed
to-true-market value higher than the ratio for other commer
cial and industrial property in the same jurisdiction. In
order to apply the Act, district courts must calculate the true
market value of in-state railroad property. A court cannot
undertake the comparison of ratios the statute requires
without that figure at hand. We said as much in Burlington
Northern: “It is clear from [the Act’s] language that in order
to compare the actual assessment ratios, it is necessary to
determine what the ‘true market values’ are.” Ibid.
We do not see how a court can go about determining true
market value if it may not look behind the State’s choice
of valuation methods. Georgia insists there is a clear and
important distinction between valuation methodologies and
their application. As the State would have it, the statute
allows courts to question only the latter. We find no distinc
tion between method and application in the language of the
Act, and see no passage limiting district court factfinding in
the manner the State proposes. The total lack of textual
support for Georgia’s position is not surprising. The dichot
omy the State presses would eviscerate the statute by forc
ing courts to defer to the valuation estimate of the State,
when discriminatory taxation by States was the very evil
the Act aimed to ban.
Georgia’s position is untenable given the way market value
is calculated. Valuation is not a matter of mathematics, as
if the district court could prevent discriminatory taxation

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simply by doublechecking the State’s assessment equations.
Rather, the calculation of true market value is an applied
science, even a craft. Most appraisers estimate market
value by employing not one methodology but a combination.
These various methods generate a range of possible market
values which the appraiser uses to derive what he considers
to be an accurate estimate of market value, based on careful
scrutiny of all the data available. Appraisal Institute, The
Appraisal of Real Estate 49–50 (12th ed. 2001).
Georgia’s appraiser in the instant case, for example, used
three different valuation techniques—the discounted cash
flow approach, a market multiple approach, and a stock and
debt approach. He derived five values from these three
methods, ranging from $8.126 billion to $12.346 billion.
After selecting a number at the low end of the range and
then subtracting another $400 million to account for intangi
ble property not subject to ad valorem taxation, he settled
on $7.8 billion as his final estimate of the true market value.
472 F. 3d, at 1284–1285.
Appraisers typically employ a combination of methods be
cause no one approach is entirely accurate, at least in the
absence of an established market for the type of property at
issue. The individual methods yield sometimes more, some
times less reliable results depending on the peculiar features
of the property evaluated. As the variation in the state ap
praiser’s market-value range reveals, different methods can
produce substantially different estimates. W. Kinnard, In
come Property Valuation: Principles and Techniques of Ap
praising Income-Producing Real Estate 52 (1971).
Given the extent to which the chosen methods can affect
the determination of value, preventing courts from scrutiniz
ing state valuation methodologies would render § 11501 a
largely empty command. It would force district courts to
accept as “true” the market value estimated by the State,
one of the parties to the litigation. States, in turn, would

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be free to employ appraisal techniques that routinely over
estimate the market worth of railroad assets. By then levy
ing taxes based on those overestimates, States could imple
ment the very discriminatory taxation Congress sought to
eradicate. On Georgia’s reading of the statute, courts would
be powerless to stop them, and the Act would ultimately
guarantee railroads nothing more than mathematically accu
rate discriminatory taxation. We do not find this inter
pretation compelling. Instead, we agree with Judge Fay in
dissent below: “Since the objective of any methodology is
a determination of true market value, a railroad should be
allowed to challenge the method[s] used [by the State] in an
attempt to prove that the result . . . was not the true market
value of its property.” 472 F. 3d, at 1294.
The State agrees that it may not be possible to fix true
market value with any precision. But it draws a different
conclusion from this premise. Because any number of esti
mates are plausible, Georgia argues, the court is as likely to
get an accurate result by verifying the application of the
State’s methods—so long as they are broadly reasonable—as
it is by employing another method altogether. The State
warns that allowing railroads to introduce their own valua
tion estimates based on different methodologies will inevita
bly lead to a futile clash of experts, which courts will have
no reasonable way to settle. At least one of the Courts of
Appeals shares this concern. See Chesapeake Western, 938
F. 2d, at 532 (“There is no absolute way to test the assertions
of competing valuations . . . ” (internal quotation marks and
brackets omitted)).
Congress was not similarly troubled. It directed courts
to find true market value, however elusive. It made that
value the objective benchmark for courts’ evaluation of state
taxes on railroad property. True market value may well not
be a single, precise number, but Congress obviously believed
it was susceptible to judicial inquiry and that some approxi
mations were better than others.

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Georgia’s grim prophecies notwithstanding, the inquiry
the statute mandates is not unfamiliar to courts. Valuation
of property, though admittedly complex, is at bottom just “an
issue of fact about possible market prices,” Suitum v. Tahoe
Regional Planning Agency, 520 U. S. 725, 741 (1997), an
issue district courts are used to addressing. Railroad prop
erty is not frequently sold, but “determinations of market
value are routinely made in judicial proceedings without the
benefit of a market transaction.” Id., at 742. The District
Court in this case made clear that it knew how to find true
market value: “In a more typical case, the court would look
at both [the railroad expert’s] appraisal and [the State’s] ap
praisal to determine the true market value of [the railroad].”
448 F. Supp. 2d, at 1338, n. 8. It refused to do so not be
cause true market value is inherently elusive, but because
it believed the Act did not allow it to question the State’s
methods.
In light of the statute’s directive making true market
value a factual question to be determined by the district
court, what Georgia is really asking for is a limitation on the
types of evidence courts may consider as part of their factual
inquiry. If Congress had wanted to impose such a limit by
reserving to States the prerogative of selecting which valua
tion methods may be used, it surely could have done so. Out
of deference to the States, for example, § 11501(c) provides
that “[t]he burden of proof in determining . . . true market
value [shall be] governed by State law.” Congress could
easily have included similar language insulating the State’s
chosen methodologies from judicial scrutiny. It did not.
Like Oklahoma’s argument in Burlington Northern, Geor
gia’s position in this case ultimately “depends upon the addi
tion of words to a statutory provision which is complete as
it stands.” 481 U. S., at 463. We decline to find distinctions
in the statute where they do not exist, especially where, as
here, those distinctions would thwart the law’s operation.

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Opinion of the Court
III
Considering the clarity of the statute, we are tempted to
leave the discussion at that. “When we find the terms of a
statute unambiguous, judicial inquiry is complete . . . .”
Rubin v. United States, 449 U. S. 424, 430 (1981). Georgia,
however, lodges two objections to our interpretation, each
of which merits a reply. First, the State argues that any
interpretation of the Act allowing courts to question state
valuation methods ignores the background principles of fed
eralism against which the statute was enacted. The major
ity below expressed a similar concern. “The selection of a
valuation methodology,” it ruled, “is part of th[e] fundamen
tal power of a state [to tax],” 472 F. 3d, at 1288, and should
not be limited absent a clear statement from Congress. We
have long held that the means States adopt to collect their
taxes “should be interfered with as little as possible.” Dows
v. Chicago, 11 Wall. 108, 110 (1871). But we are persuaded
that allowing railroads to challenge a State’s valuation meth
odologies has been clearly authorized by the terms of the
4–R Act.
As an initial matter, we question Georgia’s contention that
its selection of valuation methodologies is an important state
policy choice intimately connected to its tax power. Georgia
does not prescribe any particular methodology as a matter
of state law. Its appraisers use different methodologies in
different combinations, as they see fit. See 472 F. 3d, at
1284–1285 (explaining that the state appraiser employed
multiple methods and selected a value according to his best
judgment). This suit, in fact, is the result of an individual
appraiser’s decision to employ a different combination of as
sessment techniques than that used by his immediate prede
cessors. The methods he selected were his choice, not the
dictate of any state statute or regulation. Ibid.
But even if important questions of state policy are, as the
Eleventh Circuit believed, “intertwined with the selection of
a valuation methodology,” id., at 1288, judicial scrutiny of

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Opinion of the Court
those methodologies is authorized by the 4–R Act’s clear
command to find true market value. As we explained above,
the power to calculate true market value necessarily includes
the power to look behind a State’s valuation methods. That
the statute should vest this authority in the Nation’s courts
is hardly surprising, given Congress’s conclusion that the
States were assessing railroad property unfairly.
Our decision in Department of Revenue of Ore. v. ACF
Industries, Inc., 510 U. S. 332 (1994), is not to the contrary.
That case concerned a different provision of the 4–R Act—
namely, the command in § 11501(b)(4) preventing a State
from “[i]mpos[ing] another tax that discriminates against a
rail carrier providing transportation” in the taxing jurisdic
tion. This bar on facially discriminatory taxes, we held, did
not prevent a State from exempting certain nonrailroad
property from otherwise generally applicable ad valorem
taxes. Id., at 343. At the time the 4–R Act was adopted, a
majority of States exempted one or more classes of business
property from ad valorem taxation, “including business in
ventories, raw materials used in textile manufacturing, . . .
and mechanics tools,” to name just a few. Id., at 344. The
States had provided such property tax exemptions for years.
In the face of this widespread and historical practice, we
declined to read the 4–R Act to prohibit a type of tax exemp
tion the text did not expressly mention. Ibid.
By contrast, we pointedly noted that the Act “prohibit[s]
discriminatory tax rates and assessment ratios in no uncer
tain terms . . . and set[s] forth precise standards for judicial
scrutiny of challenged rate and assessment practices.” Id.,
at 343. Georgia’s claim that court review of state valuation
methodologies is not authorized by a clear statement in the
Act ignores the statute’s explicit prohibition of discrimina
tory assessment ratios. A district court cannot accurately
calculate or compare those ratios without determining true
market value. Congress clearly permitted courts to ques
tion state valuation methodologies when it banned discrimi

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Opinion of the Court
natory assessment ratios and made true market value a
question to be litigated in federal court.
Georgia also protests that our interpretation will destroy
the States’ discretion to choose their own valuation method
ologies. We disagree. A State may use whatever method
or methods it likes, so long as the result is not discriminatory.
The Act does not prohibit the use of any valuation meth
odology. It prohibits discrimination. Far from requiring
States to follow a particular method, we hold only that noth
ing in the statute prevents a railroad from attempting to
show that the methods chosen by the State result in a dis
criminatory determination of true market value.
The judgment of the Court of Appeals for the Eleventh
Circuit is reversed.
It is so ordered.