"Mr. Rocco estimated the subject property’s market value as of a date more than a year after the relevant January 1, 2007 valuation date that applies to the assessment under appeal. And Short Homeplace did not offer any evidence to explain how Mr. Rocco’s opinion related to the subject property’s market value-in-use as of January 1, 2007. Thus, Mr. Rocco’s appraisal lacks probative value. See O’Donnell 854 N.E.2d at 95.
The valuation date is not the only problem with Mr. Rocco’s appraisal. Despite describing his valuation approach as a sales-comparison‖ analysis, Mr. Rocco did not use comparable sales to estimate the subject property’s market value. Instead, Mr. Short hired Mr. Rocco to appraise the subject property using the assessments for the same seven properties that Mr. Short used in comparing Short Homeplace’s taxes to the taxes paid by other homeowners. While there might be circumstances under which generally accepted appraisal practices would permit using a comparable property’s assessment, instead of its sale price, in a sales-comparison analysis, it is not readily apparent what those circumstances would be. And neither Mr. Rocco nor Mr. Short did anything to address that question."
http://www.in.gov/ibtr/files/Short_Homeplace_Family_LTP_18-017-08-1-5-00001.pdf
