c) First, the Board turns to the Petitioners’ purchase of the subject property. True, the Petitioners purchased the property for $31,000 in July 2011. That purchase occurred only eight months before the March 1, 2012, which normally would lead the Board to conclude that their purchase price gives at least some indication of the property’s value on the assessment date. But here, the Petitioners’ purchase was most likely not a reliable indication of the true value of the subject property on the open market. The Board does not need to look any further than the Petitioners’ own appraisal of the property to draw that conclusion.
d) The Petitioners hired Mr. Reith, certified appraiser, who performed an appraisal in accordance with USPAP. Mr. Reith estimated the subject property’s value at $60,000 as of December 31, 2011. An appraisal performed in conformance with generally recognized appraisal principles is often enough to establish a prima facie case that a property’s assessment is over-valued. See Meridian Towers, 805 N.E.2d at 479. Further, the appraisal’s effective date is only two months removed from the assessment’s valuation date. Thus, the Board finds that the Petitioners raised a prima facie case for reducing the assessment to $60,000.
e) Once the Petitioner establishes a prima facie case, the burden shifts to the assessing official to rebut the Petitioner’s evidence. See American United Life Ins. Co. v. Maley, 803 N.E.2d 276 (Ind. Tax Ct. 2004). The assessing official must offer evidence that impeaches or rebuts the Petitioner’s evidence. Id.; Meridian Towers, 805 N.E.2d at 479.
f) The Respondent first attempted to impeach the Petitioners’ appraisal. Specifically, she claimed that the appraiser chose invalid sales in his sales-comparison analysis. However, the Respondent offered no actual evidence that the appraiser was biased or that the appraisal was flawed. It is well within an appraiser’s expertise to choose sales he deems most comparable to the property under appeal and apply adjustments to those comparable properties to value the differences between them. Absent probative evidence to the contrary, the comparable properties the appraiser chose, and the adjustments he made in a USPAP-compliant appraisal will be deemed reasonable. Conclusory statements that the appraiser used invalid sales are not sufficient to rebut the Petitioners’ case. See Hometowne Associates, L.P. v. Maley, 839 N.E.2d 269, 278 (Ind. Tax Ct. 2005) (“In none of these exchanges, however, did Mr. McHenry offer evidence rebutting the validity of Mr. Russel’s calculations. Rather, he merely made conclusory statements”). The Respondent, therefore, failed to rebut or impeach the Petitioners’ evidence that their property was over-valued for the 2012 assessment year.
g) The Respondent also tried to rebut the appraisal by offering a competing sales comparison analysis for one property, located a mile away from the subject property. She argued that this property was a better comparable because it was not a foreclosure or distress sale. The Respondent failed to make a meaningful comparison of the subject property to this comparable property. Conclusory statements that a property is “similar” or “comparable” to another property do not constitute probative evidence of the comparability of the properties. Long, 821 N.E.2d at 470. Instead, the proponent must identify the characteristics of the subject property and explain how those characteristics compare to the characteristics of the purportedly comparable properties. Id. at 471. Similarly, the proponent must explain how any differences between the properties affect their relative market values-in-use. Id.
h) The Respondent did make a few adjustments to the sales price on her comparable property. Those adjustments are not explained. While the appearance of her analysis may not differ significantly from one made by a certified appraiser in an appraisal report, the appraiser’s assertions are backed by his education, training, and experience. The appraiser also typically certifies that he complied with USPAP. Thus, the Board, as the trier-of-fact, can infer that the appraiser used objective data, where available, to quantify his adjustments. And where objective data was not available, the Board can infer that the appraiser relied on his education, training and experience to estimate a reliable quantification. There is no evidence that the Respondent is a licensed appraiser in Indiana. Moreover, she did not certify that her analysis complied with USPAP. The Board therefore finds that the Respondent’s sales-comparable analysis is insufficiently reliable to be probative of the property’s market value-in-use.
i) The Respondent did not support the assessment with substantial evidence.
j) In the alternative, the Board finds the creditability of the appraisal offered by the Petitioners to outweigh the Respondent’s evidence of value.