Ms. Castleman offered an appraisal prepared by Lance E. Krebs, a certified appraiser. Mr. Krebs used a generally accepted appraisal approach—the sales-comparison approach—to estimate the subject property’s market value at $345,000 as of March 1, 2010. And Mr. Krebs certified that he completed his appraisal in conformity with USPAP. Thus, Ms. Castleman submitted exactly the type of evidence that the Manual contemplates. She therefore made a prima facie case that the subject property was assessed too high.
In an attempt to rebut Mr. Krebs’s appraisal, the Assessor offered Phyl Olinger’s analysis of three purportedly comparable sales involving the Schellenberger, Moser, and Bohrer properties. But Ms. Olinger’s analysis has little, if any, probative weight.
For sales data to be probative, the sold properties must be 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. Similarly, one must explain how any differences between the sold properties and the property under appeal affect the properties’ relative market values-in-use. Id.
Ms. Olinger, however, did little to meaningfully compare the subject property to her three purportedly comparable properties other than to explain that they are all located in the same neighborhood and are all on the water. But other factors likely affect the subject property’s value. For example, as reflected in both Mr. Catleman’s testimony and Mr. Krebs’s appraisal, the subject property is irregularly shaped and has other issues, such as overhead wires. Yet Ms. Olinger did nothing to address those facts. Similarly, according to Ms. Olinger’s data, the subject lot has significantly more effective lake frontage than her three comparables. While Ms. Olinger apparently tried to account for that difference by using price-per-front-foot as a unit of comparison, her own data shows that price-per-front-foot dramatically decreases as the overall amount of effective frontage increases. Thus, to the extent that Ms. Olinger’s analysis is probative of the subject land’s market value-in-use, Mr. Krebs’s appraisal is more persuasive.
