The Spades offered two different calculations, both of which were based either partially or wholly on assessments from 2012 or 2013. Because the Spades did not explain how those later-year assessments relate to the property’s true tax value for 2011, their calculations have little or no probative weight.
But the Spades bought the property for $191,843 on February 11, 2011. A property’s sale price is often the best evidence of its value. See Hubler Realty Co. v. Hendricks County Assessor, 938 N.E.2d 311, 315 (Ind. Tax Ct. 2010) (finding that the Board’s determination assigning greater weight to the property’s purchase price than its appraised value was proper and supported by the evidence). That is particularly true in a case like this where the sale occurs less than a month before the relevant valuation date.
The Assessor offered no probative valuation evidence of his own to rebut that sale price. He instead simply described the procedures that were followed in computing assessments. But as the Indiana Tax Court has explained, strictly applying assessment regulations does not necessarily prove a property’s market value-in-use in an assessment appeal. See Eckerling, 841 N.E.2d at 678 (holding that taxpayers failed to make a case by simply focusing on the assessor’s methodology instead of offering market value-in-use evidence).
The Assessor likewise offered no authority for using a ratio study to prove that an individual property’s assessment reflects its market value-in-use. In fact, the International Association of Assessing Official’s Standard on Ratio Studies, which 50 IAC 27-1-4 incorporates by reference, prohibits using ratio studies for that purpose:
Assessors, appeal boards, taxpayers, and taxing authorities can use ratio studies to evaluate the fairness of funding distributions, the merits of class action claims, or the degree of discrimination. . . . .However, ratio study statistics cannot be used to judge the level of appraisal of an individual parcel. Such statistics can be used to adjust assessed values on appealed properties to the common level.
INTERNATIONAL ASSOCIATION OF ASSESSING OFFICIALS STANDARD ON RATIO STUDIES VERSION 17.03 Part 2.3 (Approved by IAAO Executive Board 07/21/2007) (bold added, italics in original).