DISSENTING OPINION BY
Senior Judge KELLEY.I respectfully dissent on two alternative theories. The facts in this matter show that Berwick Associates (Berwick) own a shopping mall in Berwick Borough. In 1999, Berwick filed a tax appeal requesting a reduction in the tax assessment for the two parcels at issue herein based upon a high vacancy rate. As a result, the assessments were reduced.
Subsequently, the vacancy rate decreased and the assessments on the two parcels were increased on June 3, 2005. Berwick appealed those assessments to the Columbia County Board of Assessment Appeals (Board) on the sole basis that “the assessment is too high when actual market value has not changed substantially.” Reproduced Record (R.R.) at 2a-3a. The Board denied Berwick’s appeals on October 3, 2005. As stated by the majority, in appealing the Board’s decision to the trial court, Berwick raised two issues: (1) whether the assessments constituted an impermissible spot assessment; and (2) whether the Board’s determination of the property’s market value was excessive. The trial court determined that the market value of the two parcels was properly set but failed to address Berwick’s contention that the Board’s action constituted improper spot assessment. Despite the trial court’s failure to address this issue, the majority reviews the same and reverses the trial court’s order.
However, by reversing, I believe that the majority has usurped the trial court’s statutory mandate. As set forth by our Supreme Court in Green v. County Board of Assessment Appeals, 565 Pa. 185, 772 A.2d 419 (2001), the General Assembly has confided to the court of common pleas pursuant to The Fourth to Eighth Class County Assessment Law1 the duties of fact finder where there has been an appeal from an assessment for taxes. As such, the trial court must hear a tax assessment appeal de novo and make its determination on the basis of the evidence put before it. Green.
In turn, this Court’s function in reviewing the decision of the trial court in a tax assessment matter is limited to determining whether the trial court abused its discretion, committed an error of law, or reached a decision not supported by substantial evidence. Id. As stated by our Supreme Court in G'reen, “[wjhile the weight of the evidence is before the appellate court for review, the trial court’s findings of fact are entitled to great weight and will be reversed only for clear error.” Id. at 196-97, 772 A.2d at 426.
Herein, although the majority acknowledges that the trial court did not address or make any factual findings with regal'd to Berwick’s contention that the Board’s action constitutes an improper spot assessment, the majority determines that such failure is harmless error and reverses the trial court’s decision based on its evalua*712tion of the evidence presented. However, such a conclusion clearly usurps the trial court’s statutory mandate and goes beyond this Court’s appellate function. As the trial court failed to fulfill its duties, I would remand for findings of fact and conclusions of law with respect to the foregoing issue.
Moreover, the Board reassessed Ber-wick’s property in 2005 after having granted it a reduction in 1999. As the record testimony reveals, the reassessment was performed because the factors which caused the tax assessment to be reduced in 1999 no longer existed in 2005. As such, I believe the trial court could properly make a finding that “the economy of the county or any portion thereof has ... appreciated to such extent that real estate values generally in that area are affected.” See Section 601.2 of The Fourth to Eighth Class County Assessment Law.2
As an alternative, I believe that the majority erred in concluding that the Board improperly reassessed Berwick’s property under The Fourth to Eighth Class County Assessment Law. The burden was on Berwick to prove that the Board’s action constituted an improper spot assessment. The term “spot assessment” is defined in Section 1.1 of what is commonly referred to as the Second Class A and Third Class County Assessment Law,3 as “[t]he reassessment of a property or properties that is not conducted as part of a countywide revised reassessment and which creates, sustains or increases dispro-portionality among properties’ assessed values.” Emphasis added. A review of the record reveals that Berwick failed to present any evidence proving that the Board’s action created, sustained or increased a disproportionality among the assessed values of other properties located within Columbia County. On this basis, I would affirm the trial court’s order.
. Act of May 21, 1943, P.L. 571, as amended, 72 P.S. §§ 5453.101-5453.706.
. Added, by Act of January 18, 1952, P.L. (1951) 2138, as amended, 72 P.S. § 5453.602a.
. Act of June 26, 1931, P.L. 1379, as amended, 72 P.S. § 5342.1.