Agency action is arbitrary, capricious, and unreasonable if it is taken in disregard of the facts or circumstances of the case, without some basis which would lead a reasonable and honest person to the same conclusion

Cain is correct that the county board of equalization has a statutory duty, informed by the principles of uniformity and proportionality set out in our State's constitution, to " `fairly and impartially equalize the values of all items of real property in the county so that all real property is assessed uniformly and proportionately

We have construed this statutory language to create a presumption in an appeal to TERC that a county board has faithfully performed its official duties in making an assessment and has acted upon sufficient competent evidence to justify its action