c. Here, the Respondent contends the property is properly valued based on the sales of comparable properties. Respondent Exhibits A, B and C. In making this argument, the Respondent relies on the sales comparison approach. See MANUAL at 3 (stating that the sales comparison approach “estimates the total value of the property directly by comparing it to similar, or comparable, properties that have sold in the market.”). In order to effectively use the sales comparison approach as evidence in a property assessment appeal, the proponent must establish the comparability of the properties being examined. Conclusory statements that a property is “similar” or “comparable” to another property do not constitute probative evidence of the comparability of the two 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.
d. In support of her argument, the Respondent submitted sales information for six properties that sold between January 2008 and February 2009. Respondent Exhibits A, B. Yet the Respondent made no attempt to show how the properties compared to the subject property and offered no explanation as to how any differences may have affected the properties’ values. Thus, the Respondent‘s evidence was not probative of the subject property’s market value-in-use. See Long v. Wayne Twp. Assessor, 821 N.E.2d 466, 471-72 (Ind. Tax Ct. 2005) (holding that sales data lacked probative value where taxpayers failed to explain how the characteristics of their property compared to the characteristics of purportedly comparable properties or how any differences between the properties affected their relative market values-in-use).
e. Next, the Respondent claimed a ratio study shows the assessments of the sold properties are relatively close to their sales prices. Respondent Exhibit C. This study is of no value in arriving at the correct assessed value for the subject property because the Respondent offered no authority for her argument that a ratio study can be used to prove that a property’s assessment reflects its market value-in-use. To be sure, 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 STANDARDS VERSION 17.03 Part 2.3 (Approved by IAAO Executive Board 07/21/2007) (bold added, italics in original).
f. The Respondent implied that the subject assessment draws validity from the fact that the disputed assessment is within an acceptable range for mass appraisals. But an appeal of an individual assessment 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. 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).
g. The Respondent did not support the accuracy of the existing assessment with any meaningful market value-in-use evidence. Accordingly, the Respondent failed to meet the burden of proof. In other cases where the Respondent had the burden of proof and failed to carry that burden, the Board has ordered that the assessment be returned to the assessed value of the year before. Therefore, the parcel’s March 1, 2009, assessment must be reduced to the 2008 assessed value of $215,000.
h. That, however, does not end the Board’s inquiry because the Petitioners sought an even lower assessed value of $190,000 for March 1, 2009. The Petitioners presented a comparative market analysis to support the requested value. The comparative market analysis is not dated and all the sales occurred in 2009 and 2010, well after the January 1, 2008, valuation date. Additionally, the real estate broker that prepared the analysis did not make any adjustments to the sold properties to account for differences between them and the subject property. For these reasons, the comparative market analysis is not probative evidence for a reduction in assessed value.
i. Next, the Petitioners presented a real estate listing for a property in their immediate neighborhood. The property was advertised on January 12, 2014, which is almost six years after the valuation date and is not indicative of the value of the subject property for March 1, 2009.
j. Finally, the Petitioners submitted a list of eight sales that occurred on their street, Crestwood Avenue. These sales took place between April 2001 and March 2004. Again, the sales are not within the required time frame for the March 1, 2009, assessment date and the Petitioners did not make any meaningful attempt to compare the properties to the subject property. The Petitioners failed to make a prima facie case for a lower value.