In a case filed with the State Tax Commission (STC) of Missouri that dates back to January 2017, T-Mobile Central, LLC, a subsidiary of T-Mobile (NASDAQ: TMUS) challenged the true value of money (TVM) assessment, and subsequent 33.33 percent of TVM tax liability, of two of its cell sites located in Holt County, MO. The two locations are referred to as the Craig site and the Oregon site. The equipment being assessed, referred to as subject property, includes “antennas, cabling, wireless network equipment, RF equipment, and electronic and power equipment.” T-Mobile does not own the towers at these sites.
The Holt County assessor originally established a TVM of $153,594 for the Craig site and $192,450 for the Oregon site. T-Mobile responded with its own internal TVM evaluation that took into account original equipment purchases, site inspections and IRS depreciation schedules along with calculations and a valuation opinion from Ernst & Young, the company’s outside accounting and audit firm. T-Mobile ultimately presented to the STC, a TVM of $41,000 for the Craig site and $34,000 for the Oregon site.
Holt County retained an engineering consulting firm, Cell Tower Solutions (CTS), to come up with an independent value assessment on the two sites based on reviews of T-Mobile documents and on-site inspections. However, the CTS engineer appointed to the case admitted that he was not an appraiser and that his rendition of the original cost of the cell tower was not an appraisal, but simply an estimate of costs of the equipment required to make a cell tower operate based upon his experience in the industry. Furthermore, the Holt County assessor was not able to reasonably substantiate the TVM methodology used to derive the figures presented to the STC.
On January 24, 2025, the STC ruled in favor of T-Mobile, concluding that the company had reasonably demonstrated that the Craig site had a TVM of $41,000 and corresponding a tax assessment of $13,666 while the Oregon site TVM was $34,000 with an assessed tax value of $11,333.
By John Celentano, Inside Towers Business Editor
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