Board Finds Sales Comparison Analysis Insufficient to Support Reduction in Property's Assessed Value

Here, the Alexanders primarily relied on sales and listing information for properties located in the subject property’s addition. Of course, sale prices for other properties do not, by themselves, show the value for a given property. But when one analyzes those sales prices using generally accepted appraisal principles, such as the sales-comparison approach, that raw data can be transformed into a reliable value indicator. See generally, MANUAL at 13-14 (describing the sales-comparison approach).

In order to effectively use a comparison approach as evidence in an assessment appeal, one must first show that the properties being examined are comparable to each other. Conclusory statements that a property is “similar” or “comparable” to another property are not probative of the properties’ comparability. Long v. Wayne Twp. Assessor, 821 N.E.2d 466, 470-471 (Ind. Tax Ct. 2005). Instead, one must identify the characteristics of the property under appeal and explain how those characteristics compare to the characteristics of the purportedly comparable properties. Similarly, one must explain how any differences between the properties affect their relative market values-in-use. Id.

The Alexanders did not offer the type of analysis contemplated by the Indiana Tax Court in Long. At most, Ms. Alexander testified that two of the purportedly comparable properties are better than the subject property. For example, she claimed that the Yount property had a better location because it backs up to the golf course, and that the Inks property has mature trees and a sprinkler system while the subject property is located next to a field and has only one small tree. But Ms. Alexander did little to quantitatively or qualitatively show how those differences affect the properties’ relative values. More importantly, Ms. Alexander simply ignored other relevant differences, most notably that the subject property is much larger than any of the three purportedly comparable properties.

Even if Ms. Alexander had offered a more reasoned analysis of her purportedly comparable sales and listings, only the sale price for the Inks property bears any relationship to the January 1, 2008, valuation date at issue in this appeal. The Yount property sold on January 7, 2010, more than two years after the relevant valuation date. And the listing for 0 Pinehurst was from March 11, 2012, more than four years after the valuation date. Yet Ms. Alexander did not try to explain how either the 2010 sale or 2012 listing relates to the subject property’s market value-in-use as of January 1, 2008. Thus, the sale and listing prices for those two properties lack probative value.

http://www.in.gov/ibtr/files/Alexander_18-017-09-1-5-00017.pdf