rental value of the land, the market value of its leasehold interest is, as the expert noted, zero.

III.

33
Accordingly, the judgment of the District Court is REVERSED and the action is REMANDED to the District Court for entry of a judgment in accordance with this opinion.



1
 The District Court also held that Metro could tax the United States only for the land actually leased by the United States to Bateson, as described in the 1974 Amendment to the Ground Lease.  Thus, the District Court found that Metro could tax the Bateson leasehold for approximately 12,563.76 square feet, rather than the 27,531 square feet that it had been using as a base figure for determining the tax assessment.  The parties do not address this holding on appeal


2
 Thissection provides:
Place and function of assessment.--The function of assessment shall be as follows, to wit:
....
(6) All mineral interests and all other interests of whatsoever character, not defined as products of the soil, in real property, including the interest which the lessee may have in and to the improvements erected upon land where the fee, reversion, or remainder therein is exempt to the owner, and which said interest or interests is or are owned separate from the general freehold, shall be assessed to the owner thereof, separately from the other interests in such real estate, which other interests shall be assessed to the owner thereof, all of which shall be assessed as real property.
Tenn.Code Ann. Sec. 67-5-502(6) (1983).


3
 This section provides in pertinent part:
Assessment guided by manuals--Factors for consideration.--(a)