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Reasonableness governed, and the tribunal's assessment increase was upheld.
On a statutory appeal from a municipal assessment tribunal, the court addressed the standard of review and the tribunal's authority to increase an assessment at a municipality's request after a taxpayer complaint.
The majority held that reasonableness applied because the issue concerned interpretation of the tribunal's home statute and no correctness category displaced deference.
Interpreting the statute purposively, the majority concluded the tribunal could change an assessment upward in this procedural context and reinstated its decision.
The dissent would have applied correctness, found the tribunal exceeded the complaint's scope, and would have remitted for a new hearing.
The appeal was allowed with costs, with a four-judge dissent.
