The GRM is the preferred method
for valuing rental properties with fewer than four units. Ind. Code §
6-1.1-4-39(b). The properties in this appeal are both single family rental properties.
The Petitioners do not live at either property.
33. The Petitioners presented the
leases for the properties under appeal, but did not provide any calculation or
analysis showing the market values of the properties based on the GRM approach.
Further, the Petitioners want to use actual rents to determine market value
based on GRM, but failed to show their rents are consistent with similar
properties in the market. See Indiana MCH, LLC v. Scott County Assessor,
987 N.E.2d 1182, 1185-6 (Ind. Tax Ct. 2013). It is necessary to consider data
from other comparable properties in order to protect against distortions and
inaccurate value estimates that might be caused by extraneous factors (such as
bad management or poor business decisions) that have nothing to do with the
inherent value of a property. Id. at 1184.
34. While critical of the
Respondent’s choice of comparable properties and the adjustments made in the
sales comparison analyses, the Petitioners failed to offer alternate analysis
or submit calculations of their own to establish values. In fact, the
Petitioners offered no analysis based on GRM, or any alternative approach
otherwise to determine value in this case. A petitioner seeking review of a
determination of an assessing official has the burden to establish a prima
facie case proving that the current assessment is incorrect, and specifically
what the correct assessment would be. See Meridian Towers East & West v.
Washington Township Assessor, 805 N.E.2d 475, 478 (Ind. Tax Ct. 2003); see
also, Clark v. State Board of Tax Commissioners, 694 N.E.2d 1230 (Ind. Tax
Ct. 1998).
35. Despite the errors in the
2010 Valuation by GRM and the mathematical errors in the sales analysis, the
Petitioners failed to establish a prima facie case for a reduction in the assessed
values for 2217 Southaven Boulevard and 2319 Southaven Boulevard. The Petitioners
offered no independent analysis or alternative approach to determine value in this
case. Where a petitioner has not supported its claims with probative evidence,
or any evidence in this case, a respondent’s duty to support these assessments
with substantial evidence was not triggered. Lacy Diversified Indus. LTD v.
Dep’t of Local Gov’t Fin., 799.
http://www.in.gov/ibtr/files/Baker_79-032-10-1-5-00002_etc.pdf
