Opinion

This matter came for trial before the court sitting without a jury on October 6, 2003. Following the presentation of evidence by the parties, the court took this matter under advisement and ordered the parties to submit post-trial briefs and an agreed statement of fact.  The parties have complied and this matter is now ripe for adjudication.  For the reasons stated below, the court FINDS that the sales ratio for other commercial and industrial property in West Virginia for the tax year 2000 is 56.1% and ORDERS the Board of Public Works to assess taxes against CSX Transportation, Inc. accordingly.