By Kevin Boyle and Tyler Mullen ( January 14, 2019, 12:55 PM EST) -- In a case decided Dec. 27, 2018, In re: Consolidated Appeals for Chester-Upland School District,[1] the Commonwealth Court of Pennsylvania addressed the question of whether revenue generated from billboard leases, rents or easements may be considered when determining a property's fair market value for tax assessment purposes. After examining the consolidated county assessment law, or CCAL,[2] the Commonwealth Court concluded that "a property's suitability to a billboard use and income earned by the property owner from the rental of the property to a billboard operator are not excluded from a fair market valuation." Said another way, the Chester-Upland opinion makes clear that the revenue generated by a property owner from a billboard lease may be considered for tax assessment purposes....