The Fullers contend that the parcels were incorrectly assessed in light of an “Appraisal report on tillable farm land and farm buildings” (“Farm Appraisal”) prepared by Sheldon Holsinger, a certified appraiser. In that Farm Appraisal, Mr. Holsinger explained that he appraised “65.95 acres in SW ¼ Section 16 of Jefferson Township, with the residence and 1.379 acres valued separately (see attached report) . . .” Pet’rs Ex. A at 1. Thus, Mr. Holsinger’s laid out his appraisal of the Fullers’ homesite in a separate “URAR report.”3 Id. at 1, 25. The Fullers did not submit that URAR report at the Board’s hearing.
…
As to the homesite, the Fullers point to a line in the Farm Appraisal where Mr. Holsinger lists that parcel as having a value of $63,500. As explained above, however, Mr. Holsinger performed a separate appraisal and prepared a separate report (the URAR report) for the homesite. Presumably, the URAR report lays out the analysis underlying Mr. Holsinger’s valuation opinion for that parcel. In any case, the Farm Appraisal does not contain that analysis. The Board is therefore left with Mr. Holsinger’s entirely conclusory assertion about the homesite’s market value, without any evidence to show that he arrived at his opinion by applying generally accepted appraisal principles. Such conclusory assertions, even when made by an appraiser, lack probative value. See Inland Steel Co. v. State Bd. of Tax Comm’rs, 739 N.E.2d 201, 220 (Ind. Tax Ct. 2000)(finding that an expert’s testimony that the Producer Price Index (“PPI”) should be used to convert obsolescence from 1993 dollars to 1985 dollars lacked probative value where the expert did not explain what the PPI represented, how it was calculated, or why it was appropriate).
In addition, the Fullers claim that the Assessor misclassified a building on the homesite as a garage when the Fullers actually use it as a hog barn. That amounts to little more than a challenge to the Assessor’s methodology in computing the homesite’s assessment. As explained above, such challenges do not suffice to rebut the presumption that a property was accurately assessed. See Eckerling, 841 N.E.2d at 678. In any case, Mr. Fuller’s brief description of the structure does nothing to show that the Assessor misclassified the structure. If anything, it tends to support the Assessor’s classification.
The Fullers also rely on Mr. Holsinger’s Farm Appraisal for their challenge to the agricultural parcels’ assessments. Of course, Mr. Holsinger appraised those parcels at $167,500, which is $90,000 more than the parcels’ combined assessment of $77,500. Thus, Mr. Holsinger’s Farm Appraisal does not help the Fullers on their claims regarding the two agricultural parcels. In fact, it is unclear whether the Fullers were even seeking to have the assessments for both those parcels lowered. On their Form 131 petition for parcel 09-06-300-012.000-014, the Fullers actually requested a total value of $89,790—almost $35,000 more than the parcel’s assessment.
The Fullers, however, also claim that the agricultural parcels were assessed based on different measurements than what Mr. Holsinger used in his Farm Appraisal. The Fullers apparently view Mr. Holsinger’s breakdown of the land into 29.93 tillable acres and 35.07 non-tillable acres as equating to the acreage contained in the respective tax parcels. But Mr. Holsinger’s breakdown between tillable and non-tillable acres was not intended as an allocation between tax parcels. To the contrary, later in the Farm Appraisal, Mr. Holsinger provided a chart showing how the 29.93 acres of tillable land was allocated between the two tax parcels—one parcel had 12.8 tillable acres while the other had 17.13 tillable acres. Pet’rs Ex. A at 4. Also, the Fullers’ reading of the Farm Appraisal ignores the additional acreage that Mr. Holsinger included in his breakdown: .5 acres “in buildings” and .45 acres “in road frontage.” Pet’rs Ex. at 1, 25. In fact, Mr. Holsinger listed a total 65.95 acres between the two parcels. That is only slightly less than the 66.13 acres listed on the parcels’ property record cards. And the Fullers offered no evidence to help the Board resolve which of the two measurements was more accurate.
Similarly, while Mr. Fuller testified that a “lean-to” included in one of the agricultural parcel’s assessments no longer exists, the relevant question is whether it existed on March 1, 2010. And the Fullers did not address that point. The Fullers therefore failed to meet their burden of proof for changing the agricultural parcels’ assessments.
