with whom WATHEN, Chief Justice, joins, dissenting.

I respectfully dissent. The evidence before the Scarborough Board of Assessment Review did not compel a decision in favor of the taxpayer. I would vacate the decision of the Superior Court and remand for the entry of a judgment affirming the Board’s denial of the Weekleys’ petition for a tax abatement.

A municipality’s property valuation is presumed to be valid. Glenridge Dev. Co. v. City of Augusta, 662 A.2d 928, 931 (Me.1995) (citations omitted). To demonstrate their entitlement to an abatement, the Weekleys had the burden of proving that the assessed valuation of their property in relation to its just value was manifestly wrong. City of Waterville v. Waterville Homes, Inc., 655 A.2d 365, 366-67 (Me.1995) (citations omitted). When the Board denies the abatement based on the taxpayers’ failure to sustain their burden of proof, the reviewing court must determine whether this negative conclusion is supported by substantial evidence on the record as a whole. Bruk v. Town of Georgetown, 436 A.2d 894, 898-99 (Me.1981). In such circumstances, the reviewing court can reverse the Board’s determination only “if the record compels a contrary conclusion to the exclusion of any other inference and, hence ... the Board’s failure to be persuaded was ‘arbitrary or capricious.’” Douglas v. Board of Trustees, 669 A.2d 177, 179 (Me.1996) (citations omitted). The record in this case does not compel such a finding.

The Weekleys’ evidence of the value of their properties before the Board consisted only of the sale price paid by the Weekleys some fifteen months earlier for lot 52 and[*935] some seven months earlier for lot 7; the sale price information concerning four purportedly “comparable” properties in the Prout’s Neck area sold between 1992 and 1993; and the opinion of the Weekleys’ real estate agent that the price paid by the Weekleys for their properties reflected their fair market value. The Weekleys presented no appraisal testimony or any other testimony to support their application for abatement.

The Weekleys’ reliance on the sale price of their property is insufficient to sustain their abatement petition. We have repeatedly held that sale price alone is not conclusive evidence of a property’s value. Rather, it is only one factor to be considered in the determination of a “just value” for tax assessment purposes. Wesson v. Town of Bremen, 667 A.2d 596, 599 n. 5 (Me.1996) (sale price of property is evidence of market value which is used in determining property value for tax assessment purposes); Shawmut Inn v. Town of Kennebunkport, 428 A.2d 384, 394—95 (Me.1981) (recent public sale is evidence of market value but the weight to be given such sale depends upon petitioner’s ability to show that sale price was indicative of price on the open market); Sears, Roebuck & Co. v. City of Presque Isle, 150 Me. 181, 188, 107 A.2d 475, 479 (1954) (actual sale shows “what is paid, not what exact value is”); Alfred J. Sweet, Inc. v. City of Auburn, 134 Me. 28, 32, 180 A. 803, 804-05 (1935) (when price is not indicative of value assessor need not rely solely on price). Cf. Kittery Electric Light Co. v. Assessors of Town of Kittery, 219 A.2d 728, 737 (Me.1966) (market value must be determined by consideration of all factors calculated to influence an assumed buyer and seller in reaching a fair market price). Despite our consistent holdings that the sale price is not conclusive evidence of property value for tax assessment purposes, the Court departs from these precedents and accords determinative weight to the sale price in reaching its conclusion that the record before the Board compelled the conclusion that the Assessor’s assessment was “manifestly wrong.”

This conclusion is especially troublesome in light of the considerable evidence presented by the Assessor, a certified Maine assessor qualified to provide expert testimony about property values, who testified that in determining the assessed values of the subject properties he had used the same appraisal methodology that he had routinely applied to all properties in the Prout’s Neck area of Scarborough. Additionally, through his testimony and the cross examination of the Weekleys’ real estate agent, the Assessor presented evidence that the four compara-bles offered by the Weekleys had been sold at something less than their market value. One lot was not listed on the open market and had been sold directly to an abutting land owner; another had been purchased by a present Prout’s Neck land owner; another of the comparables was sold by a nursing home patient who was experiencing family and financial problems; and the price of the final comparable was adversely affected by the presence of a low-quality, defective structure on the lot. Finally, the Assessor presented evidence that of the thirteen lots sold in the Prout’s Neck area from January of 1991 until August of 1993 only the Weekleys’ lots and one other lot had assessment ratios that exceeded 120%.^[1]

[*936] Based on this evidence, the Board could have reasonably drawn several conclusions. First, that the price paid by the Weekley’s for their properties was not dispositive of their current just value. Second, to the extent that the purchase price was relevant, the passage of time since the sales had further eroded the materiality and significance of the past purchase price to the determination of the current just value of these lots. Third, that the circumstances of the allegedly comparable transactions presented by the Week-leys to support their abatement petition tended to depress the price garnered from the sale of each of these properties, thereby lessening their utility as indicators of the value of the Weekleys’ lots. See Muirgen Properties, Inc. v. Town of Boothbay, 663 A.2d 55, 59 (Me.1995) (evidence that properties had no view or access to water, abutted poor quality properties and had low sale prices because they were not the result of arms-length transactions sufficiently rebutted plaintiffs contention that such properties were comparable). Fourth, that the disparity between sale price and assessed value of the Weekleys’ lots resulted not from an erroneous assessment of these lots, but rather from the transfer of the property at an abnormally low sale price.

“The petitioner for an abatement must prove his case. He must show that the property is overrated.” City of Waterville, 655 A.2d at 366 (quoting Sears, Roebuck & Co. v. City of Presque Isle, 150 Me. 181, 186, 107 A.2d 475, 477 (1954)). Based on the minimal and largely discredited evidence of just value presented by the taxpayers in this instance, thé Board could have reasonably concluded that the taxpayers had failed to provide it with credible evidence of just value, and, hence, that the taxpayers had failed to meet their burden of proof. Wesson, 667 A.2d at 599 (petitioners for abatement must provide credible evidence of just value to meet their burden of proof). This record did not compel the Board to reach a contrary conclusion and, therefore, its failure to be persuaded was not arbitrary or capricious. See Glenridge Dev. Co., 662 A.2d at 931 (quoting Camps Newfound/Owatonna, Inc. v. Town of Harrison, 604 A.2d 908, 909 (Me.1992) (“Because the taxpayer has the burden of proof, we will vacate the [Board’s] decision only if the evidence compelled [it] to grant an abatement ...”)).

I would vacate the judgment of the Superi- or Court and remand for entry of a judgment affirming the Scarborough Board of Assessment Review’s denial of the Weekleys’ petition for a tax abatement.

this sale price was for only 75% of the property.

Dropping the upper and lower quartile, the Assessor concluded that his “average assessment ratio” in the Prout’s Neck area of Scarborough was 108%. The Court, at least in part, relies on the wide disparity between the “average assessment ratio” of 108% and the assessment ratio for[*936] each of the Weekleys’ two pieces of property, 128% for lot 7 and 147% for lot 52, to support its conclusion that the record before the Board compelled the conclusion that the assessed valuation was "manifestly wrong." This reliance is misplaced.

Deviation from an average assessment ratio is not conclusive evidence of an unjust assessment. Indeed, the State of Maine Assessment Manual states that "[a]verage assessment ratios are seldom conclusive evidence of sound assessment administration.” State of Maine. Assessment Manual XI-1 (1988). The fact that the assessed values of the Weekleys' properties fell within the upper quartile of the Assessor’s sales ratio analysis is of little significance and is certainly not fatal to the Assessor’s valuation of the property. Indeed, the Weekleys’ high assessment ratio represents little more than a numerical rendition of their claim that the assessed values of their properties exceed the price they paid for these properties.

Nevertheless, the Assessor's sales ratio study does have some evidentiary value that favors the Assessor's position. Of the thirteen properties listed only three, two of which were the Week-leys’ properties, had individual assessment ratios that exceeded 120% of their sale price. The fact that the remaining properties included in the study had lower assessment ratios corroborates the Assessor’s contention that he accurately estimated property values. Moreover, in light of the demonstrated accuracy of the Assessor’s valuation method, the fact that both of the sales ratios for the Weekleys’ properties deviated so strikingly from the other assessments lends further support to the Assessor's contention that the sale price the Weekleys paid for their properties was substantially less than the market value of these properties, and, therefore, that these sale prices were not a good indication of value for assessment purposes.