Agree completely jester.
start with 108M, per the tax code counties are considered 'passing' if they hit within 90% of true market value so knock that down to $98M roughly right off the bat. valuation/appraisals are 'opinion of values' hence the wiggle room in there - all those factors jester laid out. also, the office/commercial market in general further deteriorated in the 4th quarter after the Oct sale so maybe knock a point or two off b/c of that (assessments are as of Jan 1) - fed rate went from 3ish in Oct to about 4-4.25 by start of 2023. That's an insane jump in rates over the course of a couples year much less a single quarter.
Travis CAD data says rental rates for offices of this class/age/location get about $50/ft and the building is 198,500 sq ft per that article. That would be $19,850,000 that would be paid back to the buyer over a 2 year period effectively reducing what they actually paid for the building by that amount - very simplified admittedly
interestingly enough the math works out where $98M less $19.85M in estimated leaseback payments pencils out to $78.15M vs an assessed value of $78.7M. Let me know if you have a copy of the lease or if you want to spend time filing an ORR to obtain it from TRS, happy to review that.
this is also ignoring the fair/equal provision of the tax code stating ALL property tax payers are entitled to fair/equal taxation. essentially, what they paid for the property is immaterial if they are appraised excessively more than their comp set. so even if that $108M was a kosher arms length sale, if there a bunch of apples to apples properties at $85M they would be entitled to that value (same deal for homeowners).