In this case, both parties agreed the Respondent had the burden of proving the 2006 assessment is correct.
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b. The Respondent presented no such evidence to prove the market-value-in-use of the subject property.
c. The Respondent merely claimed the subject property was assessed using the same trending factor as the other properties in the Petitioner’s neighborhood. (The Respondent, however, was unable to determine the number actually used.) Even if this claim is true, it is not helpful in determining the actual market value-in-use for this particular property.
d. The Respondent claimed the assessment/sales ratio study demonstrated some adjustment was needed to reflect the market value-in-use of properties in the neighborhood. Again, even if true, this point is of no value in arriving at the correct assessed value for this particular property. The Assessor offered no support for the notion that a ratio study can be used to prove an individual property’s assessment reflects its market value-in-use. Indeed, the International Association of Assessing Officers Standard on Ratio Studies, which 50 IAC 27-1-4 incorporates by reference, says otherwise:
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 OFFICERS STANDARD ON RATIO STUDIES VERSION 17.03 Part 2.3 (Approved by IAAO Executive Board 07/21/2007) (bold added, italics in original).
e. The Respondent claimed she met her responsibilities by providing the assessment/sales ratio study was approved by state officials. The Respondent implied that the subject assessment draws validity from the fact that the disputed assessment is within an acceptable range for mass appraisals. An appeal of an individual assessment, however, is an entirely different thing. The Respondent provided no authority or substantial explanation for the conclusion that there is an acceptable range for establishing the value of property for the purposes of this appeal. Her unsubstantiated conclusions do not constitute probative evidence. Whitley Products, Inc. v. State Bd. of Tax Comm’rs, 704 N.E.2d 1113, 1119 (Ind. Tax Ct. 1998).
f. The Respondent did not support the accuracy of the existing assessment with any meaningful market value-in-use evidence. Accordingly, she failed to meet her burden of proof. Therefore, the parcel’s March 1, 2006, assessment must be reduced to the 2005 assessed value.
