Manchester relied on Ms. Praul’s
valuation opinion in which she backed into a price-per-square-foot for all of
the units in their unfinished state by subtracting the costs for finishing 251
Wakefield Way from that unit’s sale price. In doing so, Ms. Praul made several
assumptions. For example, she assumed that the costs for finishing the units
would necessarily contribute dollar-for-dollar to their eventual sale prices.
The record, however, offers little support for that assumption. More
importantly, the record does not support Ms. Praul’s assumption that 251
Wakefield Way was unfinished on March 1, 2011. Heritage took many
draws—including draws for work associated with what Ms. Praul described as
remediation for the building’s exposure to the elements—well before the March
1, 2011 assessment date, and it took the rest of the draws on March 8, 2008.
The record is silent about
whether Heritage took its draws before or after work was completed, but the
fact that the sale of 251 Wakefield Way closed on April 6, 2011, supports an
inference that the unit was finished in advance of that date and may have been
completely, or almost completely finished on March 1, 2011. Yet Ms. Praul used
that unit’s unfinished price-per-square-foot in her analysis. Similarly, the
record does not support Ms. Praul’s claim that Heritage waited to remediate
damage to the other units until after March 1, 2011. Indeed, Mr. Knighton
testified that he did not “have a clue” whether the damage had been remediated
before or after March 1, 2011, but that at some point “we did go in and
remediate everything that we knew needed to be done.” Knighton testimony.
At the end of the day,
Manchester seeks a value that is close to the property’s actual assessment. And
the assessment already reflects that the condominium units were only partially
completed. Given the difficulty of the valuing an unfinished building, Ms.
Praul asks us to draw a fine line. The lack of support for key assumptions
underlying her methodology, however, prevents us from drawing that line. Under
those circumstances, Ms. Praul’s analysis lacks probative weight.
Finally, Manchester contends
that subject property’s lower assessment for 2012 shows that it was assessed
too high in 2011. But each assessment and each tax year stands alone. Fleet
Supply, Inc. v. State Board of Tax Commissioners, 747 N.E.2d 645, 650 (Ind.
Tax Ct. 2001) (citing Glass Wholesalers, Inc. v. State Board of Tax
Commissioners, 568 N.E.2d 1116, 1124 (Ind. Tax Ct. 1991)). Thus, evidence
as to a property’s assessment in one tax year generally is not probative of its
true tax value in a different tax year. There are various reasons why a
property’s value might change from one year to the next, and Manchester had the
burden of proving that the assessment for the year under appeal was wrong. As
already explained, Manchester failed to meet that burden.
