Volume 115 — New Hampshire Reports

1. A taxpayer seeking an abatement in the superior court or before the board of taxation is not entitled to the abatement unless he proves that the disputed assessment is disproportionately higher than that of other property within the taxing district. 2. A limited appeal from an administrative board should not be governed by the rules applied to the broader appeal available from a court decision. 3. The board of taxation has concurrent jurisdiction with the superior court to hear taxpayers' appeals for tax abatement. 4. Decisions of the board of taxation may be appealed by either the town or city or the taxpayer to the supreme court where the findings of fact by the board are final and review by the supreme court is limited to questions of law. 5. The State's administrative procedure act (RSA ch. 541-A) does not contain a requirement for findings of fact; but the requirement of administrative findings was created by courts and is a part of the common law, and the board is under a duty to find all facts essential to the presentation of all questions of law raised by its order so that the supreme court may insure that the board's decisions are lawful.<page_number>Page 132</page_number>