672 S.E.2d 174
Benjamin, J., dissenting:
For the reasons set forth in my dissenting opinion in In re: Tax Assessment of Foster Foundation's Woodlands Retirement, No. 33891, I respectfully also dissent in this case. I believe that the proper burden of proof for a taxpayer in a case such as this is that the taxpayer meet a preponderancy of the evidence burden. I therefore dissent to the majority opinion.