Here, Parker-Hannifin presented an appraisal report,
prepared by Brent Overholt, that estimated the subject property’s value at
$3,068,000 as of March 1, 2010. Mr.
Overholt is an Indiana Certified General Appraiser who prepared the appraisal
in accordance with USPAP. The appraisal
conforms to the correct valuation date for the March 1, 2010, assessment and,
along with Mr. Overholt’s testimony, also sufficiently relates to the March 1,
2011, assessment date. An appraisal
prepared according to USPAP will often be probative of a property’s value. See Kooshtard Property VI, LLC, 836 N.E.2d at
506 n.6. Parker-Hannifin has therefore
made a prima facie case that the subject property’s assessment should be
reduced to its appraised value for the 2010 and 2011 assessment years.
The Assessor attempted to impeach Parker-Hannifin’s
appraisal by two means. First, the Assessor
offered another appraisal prepared by Mr. Overholt, in which he used many of the
same comparables in the respective sales-comparison approaches, but arrived at significantly
different adjusted values. The Assessor
argues that since the market value should be the same no matter the appraisal’s
purpose, the discrepancy in values damages Mr. Overholt’s credibility. But the Assessor clearly misses the
mark. As Mr. Overholt correctly
explained, the sales-comparison grid’s purpose is not to determine the value of
the comparable properties, but to adjust their sale prices for differences
between the comparable properties and the subject property to estimate a value
for the subject property. Thus, the
reason for the differences in the adjusted values is that the Petitioner’s
property differs from the Peg Perego property.
Second, the Assessor contends that the Board should give
little weight to ParkerHannifin’s appraisal because Mr. Overholt used
foreclosure sales and sale-leaseback transactions in his sales-comparison
approach. In addition, the Assessor
argues that some of the sales were for properties located outside of Allen
County. The Board, however, finds this
argument unpersuasive. It is well within
an appraiser’s expertise to choose the sales he or she deems most comparable to
the subject property and apply adjustments to those comparable properties to
value differences between them. Here,
while Mr. Overholt acknowledged that a few of his comparables were
foreclosure sales or sale leasebacks, he testified that those types of sales
were a significant part of the market.
Further, he made adjustments to those sales for the
conditions or terms of the sales. Absent
evidence to the contrary, the comparable properties chosen by the appraiser,
the weight given to the sales, or the adjustments made by an appraiser in a
USPAP-compliant appraisal are deemed to be reasonable.
The Assessor also attempted to rebut Parker-Hannifin’s
appraisal with competing sales comparison and income-capitalization
computations. While the two parties
followed very similar formats in valuing the property, the Assessor computed a
significantly higher value in both approaches.
This appears to be mainly due to differences in adjustments in the
sales-comparison approach, and a difference in the capitalization rate used in
the income approach. Thus, the Board is
left with determining which of the competing analyses is more probative of the
subject property’s value.
While Mr. Overholt certainly could have done a better job
explaining his adjustments and computations, particularly in cross-examination,
the Board still finds that Mr. Overholt’s value estimate is better supported
and explained overall. Moreover, Mr.
Overholt is a licensed appraiser who certified that his value estimate is
USPAP-compliant. The Assessor’s evidence
lacks those credentials. Consequently,
the Board finds for ParkerHannifin, and orders that the subject property’s
assessment be reduced to $3,068,000 for both March 1, 2010 and March 1, 2011.
