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net income using an overall rate of 15.25 and found a value of <br />$224,000. <br />Petitioner, in adapting Mr. Patchin's income approach, <br />testified that net income should not exceed 2.5% of 1992 gross <br />sales, relying on this Court's decision in Carson Pirie Scott & <br />Co. v. County of Dakota, File Nos. C7-90-7005, C4-92-7192 and C6- <br />93-7673 (Minn. Tax Ct. July 5, 1994). Petitioner argues that the <br />Carson case supports the use of 2.50 of gross sales for a <br />department store market rent. We f ind that in Carson we <br />concluded only that 2.50 of gross sales was an appropriate market <br />rent for the Burnsville Center's Carson Pirie Scott store for the <br />years at issue. Petitioner's store is not comparable to a major <br />department store operating on a regional level in a major <br />regional mall. Mr. Patchin's market rent figure of $42,962 is <br />comparable to 4.9~ of gross sales and is appropriate for the <br />subject property. <br />Petitioner points out that Mr. Patchin's cap rate includes <br />the lower tax rate which is applied to the first parcel of <br />commercial property per owner in each county and argues that the <br />higher, overall rate for commercial property is more appropriate. <br />However, Petitioner did not present us with authority for this <br />position and Mr. Patchin used the tax rate actually applied to <br />the property. Therefore, we accept Mr. Patchin's cap rate. <br />Ultimately we conclude that Petitioner's conclusion of value <br />is not credible. Although Petitioner relied on Mr. Patchin's <br />• expert methodology, Petitioner is not an appraiser and has no <br />8 <br />