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Here, the Petitioner relies solely on Mr. Taylor’s analysis in attempting to prove that the subject property’s assessment is too high. Mr. Taylor based his value estimate on the sales and listings of six purportedly comparable St. Joseph County restaurant properties. Thus, the Petitioner recognizes that, through the sales-comparison approach, one can estimate the value of a property by analyzing the sales of comparable properties. A party offering such evidence must show that the properties are generally comparable to each other, and also must show how any relevant differences affect the relative values. See Long, 821 N.E.2d at 470-71 (holding that, in applying the sales-comparison approach, the taxpayers needed to explain how any differences between their property and the properties to which they sought to compare it affected the properties’ relevant market values-in-use).
Mr. Taylor did attempt to compare the properties to the subject and adjust for differences. Further, he documented the various types of data he relied on to make those adjustments, which he expressed in percentage form. He relied on current property record cards to make land size and land-to-building ratio adjustments. In making his adjustments for age and weighted use types, Mr. Taylor relied on cost and depreciation tables from the 2012 Guidelines. And he relied on traffic count data to make adjustments for location.
However, Mr. Taylor’s hodgepodge of assessment, appraisal, and mathematical methodology does not persuade the Board the evidence is based on generally accepted appraisal or assessment practices. Mr. Taylor’s testimony does not sufficiently flush out the details of the adjustments. Furthermore, he does not
reference any authorities that might confirm that the methodology and data were applied according to accepted appraisal practices. The Board therefore finds that the Petitioner’s sales comparable analysis is insufficiently reliable to be probative of the property’s market value-in-use.
http://www.in.gov/ibtr/files/Full_Service_Dining_71-005-09-1-4-01613.pdf
