The central tenet of the cost approach is the principle of substitution: an informed buyer will pay no more for a property than the cost to acquire a similar site and construct improvements of like desirability and utility. The burden of proving the invalidity of agency action is on the party asserting invalidity.

Thus, this court must determine whether the evidence supporting the agency's factual findings is substantial when considered in light of all the evidence. The term 'in light of the record as a whole' is statutorily defined to include the evidence both supporting and detracting from an agency's finding. In reviewing the evidence in light of the record as a whole, this court does not reweigh the evidence or engage in de novo review. This court reviews a decision from the Court of Tax Appeals in the manner prescribed by the Kansas Judicial Review Act, K.S.A. for the Year 2012 in Sumner County, Kansas. 111,650 IN THE COURT OF APPEALS OF THE STATE OF KANSAS In the Matter of the Equalization Appeal of KANSAS STAR CASINO, L.L.C.

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