CPF Investments bought a Fulton County residence from Freddie Mac for $207,000 in 2011 and argued that Georgia law capped the property’s fair-market value for the 2012 tax year at that arm’s-length sale price. The Fulton County Board of Assessors valued the property at $370,400, later reduced to $340,000, and contended that sales involving government agencies could never qualify as bona fide transactions. The trial court accepted that theory and denied CPF’s summary-judgment motion. The Court of Appeals of Georgia reversed. OCGA § 48-5-2(3) contains no exemption for government agencies and sets a qualifying sale price as the ceiling for the next tax year’s assessment. The Board therefore could not rely on a categorical presumption; it had to produce evidence of fraud, affiliation, or other facts showing that the sale was not arm’s length. CPF supplied an affidavit supporting an open-market transaction, while the Board offered only its unsupported presumption. The court reversed and remanded for entry of judgment for CPF and consideration of attorney fees, without deciding whether Freddie Mac was itself a government agency.