The parties met their respective
burdens of production by offering USPAP certified appraisals that, at first
blush, were performed in conformance with generally recognized appraisal
principles and that the parties at least attempted to relate to the appropriate
valuation date. After weighing the evidence, the Board finds that the subject
property’s true tax value is $480,000. The Board reaches that conclusion for
the following reasons:
a. First, the Petitioner offered
three valuation opinions that have little or no probative value—Wykoff’s market
analyses and Nicholson’s appraisal. Although Wykoff applied a generally
recognized appraisal technique, she did not certify she complied with USPAP.
And she offered little explanation for key judgments underlying her
conclusions. For example, Wykoff made what she described as a conservative
$10,000 adjustment to the sale prices for two of her three comparable
properties to account for the lack of “upgrades” similar to those found in the
subject home. But she did not explain what those upgrades were or how she
arrived at her adjustment.
b. Nicholson’ appraisal fares no
better. As highlighted by the parties, his appraisal contains various
inaccuracies and contradictions that make his ultimate valuation opinion
unreliable. Even if the Board were to find Wilson’s attempts to correct some of
Nicholson’s errors persuasive, which it does not, those corrections would do
little to shore up Nicholson’s valuation opinion. The problems that the parties
identified leave the Board with little confidence in Nicholson’s judgment.
c. That leaves Waynick’s
appraisal and Murdoh’s two appraisals. All three appraisals are generally
credible. The fact that neither appraiser testified makes it more difficult for
the Board to weigh their respective opinions. With one exception, each
appraisal relies on different comparable sales. The exception— 116 Erie Church
Road—is the first comparable sale in both Waynick’s appraisal and Mordoh’s
second appraisal. Even then, Waynick and Mordoh made different adjustments to
that property’s sale price. For example, Mordoh viewed the subject home as
superior to the Erie Church Road home in terms of construction quality and
therefore adjusted the sale price upward by $50,000. Waynick, by contrast,
viewed the homes as being of comparable quality and made no adjustment. The
record does not contain sufficient information about the Erie Church Road home
for the Board to judge which appraiser better captured the relative quality of
the two homes. The same is true for differences in how the two appraisers
quantified their adjustments.
d. The Board, however, does find
Mordoh’s treatment of age differences between the subject home and comparable
homes to be more persuasive than Waynick’s treatment of those differences.
Mordoh made adjustments to account for differences between the subject home’s
age and the ages of his comparable homes. By contrast, Waynick did not adjust
any of his comparable sale prices to account for age differences, even though
two of his comparable homes were 12 and 42 years older than the subject home,
respectively. Absent any explanation for that decision, the lack of age
adjustments in Waynick’s appraisal makes his valuation opinion less credible
than Mordoh’s opinion.
e. In addition, Mordoh’s second
appraisal actually estimates the subject property’s value as of the relevant
March 1, 2010 valuation date using sales that were closer to that date than
were the sales from both Waynick’s appraisal and Mordoh’s first appraisal.
Granted, Waynick also used one sale from 2010 in his appraisal. And Wilson and
Reller used changes in gross assessed values for all properties within Marion
Township to trend Waynick’s appraisal and Mordoh’s first appraisal to the
appropriate valuation date. But those changes do not necessarily relate directly
to changes in market. For example, they might be attributable partly to new
construction within the township. Regardless, the Board finds Wilson and Reller’s
trending methodology less persuasive than Mordoh’s targeted estimate, in which
he used sales that were largely within less than a year of the valuation date. Thus,
the Board is most persuaded by Mordoh’s second appraisal, which values the
subject property at $480,000 as of March 1, 2010.
