Petitioner National City Bank of Michigan/Illinois filed apetition for review of the 1997 and 1998 real estate assessmentsof certain property owned and partially occupied by petitioner. The Illinois Property Tax Appeal Board (PTAB) ruled that nochange in the assessments was warranted and this appeal followed. We affirm.

In 1996, the subject property consisted of a six-storymulti-tenant commercial office building located in the centralbusiness district of Kankakee, Illinois. After the property wasassessed at $1,375,497 (reflecting a fair market value of$4,165,648 and an assessment level of 33.02%), petitioner soughtreview by the PTAB. Petitioner submitted an appraisal report byJohn Mundie indicating that the value of the property was $2million. The Kankakee County Board of Review (Board) submittedan appraisal report by Roger Tibble estimating the property at$2,570,000. The PTAB found Mundie's appraisal to be morecredible, in part because, unlike Mundie, Tibble was not presentat the hearing and therefore could not be cross-examined. ThePTAB reduced the assessed valuation of the subject property to$660,400, reflecting a fair market value of $2 million. TheBoard appealed that decision and this court affirmed.

In 1997, at petitioner's request, the subject property wascombined with four other parcels of property that included adrive-up banking facility, a parking garage and a parking lot. The combined properties were issued a new property identificationnumber and were assessed as a single parcel. This parcel wasassessed at $1,753,158 in 1997 and 1998, representing a fairmarket value of approximately $5.3 and $5.2 million in thoseyears. Petitioner sought review of the 1997 and 1998 assessmentsfrom the PTAB.

At the hearing on September 22, 2000, petitioner presentedthe complete narrative appraisal report and testimony of JohnMundie. Mundie's report was the same one that had been submittedin the prior proceedings concerning the 1996 taxes, and hetestified that there had been no significant change in the valueof the property. Mundie's appraisal report included all three ofthe accepted approaches of estimating value: the cost approach,the income approach and the sales comparison approach. Of thethree, Mundie gave the greatest weight to the income approach,primarily due to the lack of comparable sales in the Kankakeearea. Mundie estimated the value of the property at $2 million.

On cross-examination, Mundie testified that he was not awarethat the parcel containing the office building had beenconsolidated with four other parcels in 1997. After learning ofthe consolidation, Mundie acknowledged that his appraisal waslimited to the office building and did not include the otherparcels. Petitioner's counsel agreed that Mundie's testimony wasbeing offered only with respect to the portion of the propertycontaining the office building. Mundie was not asked if hisopinion of the value of the office building would have beenaffected by the consolidation.

The only other witness called by petitioner was David West,the Kankakee Township assessor. West testified that in 1996 theassessed valuation of the office building was $1,375,497. Afterconsolidation the office building was again valued at $1,375,497in 1997 and 1998, although that figure represented only a portion(approximately 78%) of the overall assessed valuation of thecombined parcels. The assessed valuation of the drive-up bankand the parking garage were higher in 1996 than after the 1997consolidation. West testified that the property assessment wasbased on looking at the property as a whole and how each parcelcomplemented the others.

When West was asked if there had been a sale or transfer ofthe ownership of the property, he indicated that ownership of theoffice building was transferred in the year 2000 for $1,000,050. West did not believe that the transfer included the land, justthe building. When West was recalled as a witness for the Board,he stated that the transfer was a sale and leaseback, which wasnot considered an arm's length transaction. West also testifiedthat he valued the property by relying on previous assessedvaluations and by comparing the property to the most comparableproperty in the township, the Executive Office Center.

The Board's primary witness was appraiser Raymond Rogers. Rogers prepared a limited restricted appraisal report, which hedescribed as a "cursory review" that analyzed a property's mostimportant features. Rogers testified that his appraisal includedthe office building, the parking garage, the drive-up facilityand the approximately 1.7 acres that comprised the entireproperty. According to Rogers, the parking garage and the drive-up facility complement the office building and enhance its value. Rogers based his opinion of the value of the property on ananalysis of the estimated income of the property and on marketsales of other offices, bank buildings and mixed-use buildings. Rogers visited the property three times and inspected the officebuilding, the drive-up facility and the parking garage. Rogersvalued the property at $4.4 to $4.6 million.

Rogers criticized Mundie's appraisal on a number of grounds. For example, Rogers believed that Mundie's failure to classifythe office building as a banking facility resulted in lower rentprojections, a lower sales price and a diminished value. Bankbuildings cost more to build and they rent and sell for more dueto upgraded flooring, marble walls, hardwood trim, built-invaults and safety deposit rooms and high-grade security systems. According to Rogers, none of the rental and sales comparablesused by Mundie were similar to the subject property, as they werepure office buildings, not banking facilities.

The PTAB found that no reduction in the assessment of thesubject property was warranted because petitioner failed to proveby a preponderance of the evidence that the property wasovervalued. The PTAB noted that Mundie's appraisal representedonly a portion fo the property and petitioner presented noevidence regarding the value of the whole parcel. In rejecting a"piecemeal approach" to valuing the property, the PTAB cited thetestimony of both West and Rogers indicating that it would beincorrect to value only a portion of the property because thatvalue would be affected by the other parcels. The PTAB alsonoted that its decision to lower the assessed valuation in 1996related to the office building alone, and the evidence andtestimony at the current hearing were different. The PTAB wasalso persuaded by Rogers' criticism of Mundie's failure to valuethe property as a banking facility. The PTAB disregarded thesale and leaseback transaction that occurred in 2000 because itwas not an arm's length transaction and did not reflect truemarket value. The PTAB concluded that the value of the propertyas it had been assessed was fairly reflective of market valuebased on the property record cards, the testimony of Rogers andWest, and Rogers' limited appraisal report.

When conducting administrative review, a reviewing courtaccepts the agency's findings and conclusions on questions offact as prima facie true and correct. 735 ILCS 5/3--110 (West1998). A reviewing court is not to reweigh the evidence,reassess the credibility of the witnesses, or substitute itsjudgment for that of the agency. Residential Real Estate Co. v.Property Tax Appeal Board, 188 Ill. App. 3d 232, 543 N.E.2d 1358(1989). The scope of review is limited to determining whetherthe administrative agency's findings are against the manifestweight of the evidence. See Abrahamson v. Illinois Department ofProfessional Regulation, 153 Ill. 2d 76, 606 N.E.2d 1111 (1992). A reviewing court is not justified in reversing an administrativeagency merely because it might have ruled differently or becauseanother conclusion is reasonable (Abrahamson, 153 Ill. 2d 76, 606N.E.2d 1111); a finding is against the manifest weight of theevidence when all reasonable and unbiased persons would agreethat the opposite conclusion is clearly evident (La SallePartners, Inc. v. Illinois Property Tax Appeal Board, 269 Ill.App. 3d 621, 646 N.E.2d 935 (1995)). The party contesting anassessment bears the burden of going forward; it must providesubstantive, documentary evidence or legal argument sufficient tochallenge the correctness of the assessment. 86 Ill. Adm. Code.