The valuation date for a 2006 assessment was January 1, 2005. IC 6-1.1-4-4.5; 50 IAC 21-3-3. Any evidence of value relating to a different date must also have an explanation about how it demonstrates, or is relevant to, that required valuation date. Long, 821 N.E.2d at 471.
Therefore, the sale price of $95,900 in May 2008 is not probative evidence for this case because nothing in the record relates it back to the required valuation date, which was more than three years earlier. The record does not establish what kind of movement there might have been with general market conditions during that time. Furthermore, the Petitioners spent over $21,000 on repairs prior to that sale. The record lacks substantial evidence or explanation to form any legitimate conclusion about a more accurate value for the subject property three years earlier and before the repairs.
Much of the Petitioners’ case merely focused on the condition of the property. Mr. Terry’s testimony credibly established that the subject property was in very poor condition until the Petitioners started fixing it up. We conclude that on the assessment date the property was in an unrentable and unlivable condition. The Property Record Card indicates the subject property was in average condition, but the evidence indicates it really was not that good. The Assessment Guidelines have six condition ratings from excellent to very poor. REAL PROPERTY ASSESSMENT GUIDELINES FOR 2002—VERSION A, app. B at 7 (incorporated by reference at 50 IAC 2.3-01-2). Determining a condition rating for the subject property, however, is just one of the many steps in the Guidelines. It does not directly answer the essential question, which is value.
The Petitioners failed to make their case based on the evidence and arguments related to condition. Even if the condition of the subject property really was “very poor” on March 1, 2006, that point does not prove what a more accurate value is. One cannot make a case based on whether the Guidelines were applied properly. Eckerling v. Wayne Twp. Assessor, 841 N.E.2d 674, 677 (Ind. Tax Ct. 2006). Again, to successfully make their case they needed to show the assessment does not accurately reflect market value-in-use. Id.; see also P/A Builders & Developers, LLC v. Jennings County Assessor, 842 N.E.2d 899, 900 (Ind. Tax Ct. 2006) (explaining that proper focus is not on methodology, but rather, on what the correct value actually is). They did not do so.
