The Petitioners offered a variety of evidence and arguments in an attempt to show that the subject parcels were assessed too high. Much of that evidence, however, lacks probative value. For example, while they pointed to factors that they felt detracted from the subject parcels’ value, the Petitioners did not attempt to quantify their effect or otherwise explain how those factors led to the particular values that were requested.
Nonetheless, the Petitioners offered Lawrence Culp’s appraisal report, in which Mr. Culp valued each lot at $17,000 as of March 1, 2010. Mr. Culp certified that he performed his appraisal in conformance with USPAP. Consequently, the Petitioners made a prima facie case that the subject parcels’ assessments should be $17,000 for each of the two lots.
The burden therefore shifted to the Respondent to impeach or rebut the Petitioners’ case. While Mr. Culp appraised the parcels separately and they are assessed separately, the Respondent contends that the parcels should be viewed together as one property.
First, the Respondent points to another appraisal, which Mr. Culp completed in 2008, valuing the parcels together at $57,500. That appraisal’s effective date, however, is nearly two years before the relevant March 1, 2010, valuation date. Thus, it is not probative of the parcels’ value or use for the 2010 assessment.
The Respondent further points to the current sales listing for the subject parcels and notes that the parcels are being marketed as one property. The Respondent argues that the $49,900 listing price is much higher than Mr. Culp’s appraised value of the parcels separately.
The parties agree that the subject parcels are more valuable and desirable in the market when considered together rather than separately. Consequently, the Respondent argues the parcels should be assessed as one property. In a sense, the Respondent contends that the subject parcels should be valued according to their highest and best use. The Respondent is incorrect. As stated above, true tax value is defined as the market value-in-use of a property for its current use, not its highest and best use. See MANUAL at 2. There is, therefore, no inherent requirement to value the subject parcels as one property just because they are worth more when marketed together. The Respondent failed to impeach Mr. Culp’s appraisal on that argument alone.
There is little in the record regarding the Petitioners’ current use of the parcels. If anything, the parties seem to agree that the Petitioners do not use the parcels at all. Thus, the Board is left with determining the best valuation evidence on the record, regardless of whether that evidence values the parcels together or separately. Here, the best evidence is clearly Mr. Culp’s March 1, 2010, appraisal. Thus, the Board finds that based on Mr. Culp’s appraisal, the subject parcels’ March 1, 2010, assessments should be reduced to $17,000 each.
