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).
