Because each lot’s March 1, 2008 assessment increased by more than 5% over the previous year, the Assessor had the burden of proving that the parcels’ assessments were correct.
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Here, the Assessor did little to support the land assessments for the Thieles’ lots. She primarily relied on the sales prices for nearby parcels owned by JPR Investments, LLC, O’Connells, and the Pequignots. Granted, one can show a property’s value through sales information for comparable properties; that is precisely what the sales-comparison approach contemplates. See MANUAL at 3 (explaining that the sales-comparison approach “estimates the total value of the property directly by comparing it to similar, or comparable, properties that have sold in the market.”). For sales data to be probative, however, one must show that the sold properties are sufficiently comparable to the property under appeal. Conclusory statements that a property is “similar” or “comparable” to another property do not suffice. See Long v. Wayne Twp. Assessor, 821 N.E.2d 466, 470 (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 sold properties. Id. at 471. One must similarly explain how any differences between the sold properties and the property under appeal affect the properties’ relative market values-in-use. Id.
Aside from showing their proximity to the subject parcels, however, the Assessor did nothing to meaningfully compare the JPR Investment’s, LLC, O’Connell’s, or Pequignot’s lots to the Thiele’s lots terms of characteristics that would tend to affect their relative market values-in-use. The Assessor’s sales data therefore lacks probative value.
Because the Assessor did not offer any probative evidence of the lots’ market values-in-use, she failed to meet her burden and the lots’ March 1, 2008 land assessments must be reduced to their March 1, 2007 levels as follows:
