The most effective method to establish value can be through the presentation of a market value-in-use appraisal, completed in conformance with the Uniform Standards of Professional Appraisal Practice. Kooshtard Property VI, LLC v. White River Twp. Assessor, 836 N.E.2d 501, 506 n. 6 (Ind. Tax Ct. 2005).
The
Respondent successfully made a prima facie case that the assessment is correct.
Mr. Sceifers’ 2011 appraisal at $27,000 is relevant, probative evidence that
the value of the subject property was at least $23,500 as of March 1, 2011.
Once
the Respondent establishes a prima facie case, the burden shifts to the
Petitioner to rebut the Respondent’s evidence. See American United Life Ins.
Co. v. Maley, 803 N.E.2d 276 (Ind. Tax Ct. 2004). The Petitioner must offer
evidence that impeaches or rebuts the Respondent’s evidence. Id.; Meridian
Towers, 805 N.E.2d at 479.
The
Petitioner presented statements of value from two mobile home dealers that the
Petitioner’s mobile home is of no value. But the appraisal also placed little
or no value on the mobile home. Because neither party attributed any value to a
mobile home, these statements from the mobile home dealers do nothing to show
error in the appraisal presented by the Respondent.
The
Petitioner purchased the property for $38,601 in July 2008. In original tax
appeals, however, each assessment and each tax year stands alone. See
Thousand Trails Inc. v. State Bd. of Tax Comm’rs, 747 N.E.2d 1072, 1077
(Ind. Tax Ct. 2001). Nothing in the record relates this purchase price to the
relevant valuation date of March 1, 2011. Accordingly, this evidence is of no
probative value. Long, 821 N.E.2d at 471.
According
to the Petitioner, the assessment contains errors in total acreage, a lack of a
negative influence factor, grade, and air conditioning. Even if that claim is
true, the Petitioner failed to make his case by simply contesting the
methodology used to compute the assessment. To successfully make his case he
needed to show the assessment does not accurately reflect the subject
property’s market value-in-use. Eckerling v. Wayne Twp. Assessor, 841
N.E.2d 674, 677 (Ind. Tax Ct. 2006); see also P/A Builders & Developers,
LLC v. Jennings County Assessor, 842 N.E.2d 899, 900 (Ind. Tax Ct. 2006)
(explaining that proper focus is not on methodology, but rather on what the
correct value actually is).
The
Petitioner did not present substantial, probative evidence to support his claim
for an assessment of $20,210. Furthermore, he failed to rebut the value proved
by the Respondent.
