23. Mr. Rubin relied solely on data from the sales of ten
other properties. A property’s value may be estimated directly by comparing it
with similar properties that have sold in the market. Indeed, that is what the
sales comparison approach—one of the three generally accepted appraisal
approaches—does. But to use that approach in an assessment appeal, one must
show that the sold properties are comparable to the property under appeal.
Conclusory statements that a property is “similar” or “comparable” to another
property do not suffice. Long v. Wayne Township Assessor, 821 N.E.2d 466, 470 (Ind.
Tax Ct. 2005). Instead, one must identify the characteristics of the property
under appeal and explain both how those characteristics compare to the
characteristics of the purportedly comparable properties and how any relevant
differences affect the relative market values-in-use. See id
at 471.
24. Mr. Rubin’s spreadsheet shows the following information
for each of his ten purportedly comparable properties: the property’s address;
the number of bedrooms, bathrooms, and total rooms; the total area; and the
sale price both in absolute terms and per square foot. Although the spreadsheet
data might allow a comparison of Mr. Rubin’s purportedly comparable properties
to the subject property in terms of at least some characteristics that likely
affect value, he did not walk the Board through that comparison. See
Indianapolis Racquet Club, Inc. v. Washington Twp. Assessor, 802 N.E.2d 1018,
1022 (Ind. Tax Ct. 2004) (“[I]t is the taxpayer's duty to walk the Indiana
Board . . . through every element of the analysis”). And he offered no data
regarding various other relevant characteristics, such as the relative ages of
the houses.
25. More importantly, Mr. Rubin did not attempt to explain
how relevant differences between the purportedly comparable properties and the
subject property affected their market values-in-use. He simply took the
average sale price and applied it to the subject property. Because Mr. Rubin
did not show that his valuation analysis complied with generally accepted
appraisal principles, his sales data lacks probative value.
26. Mr. Rubin, however, did show that Lot 48 has only 45
feet of frontage rather than 50 feet. The Board therefore orders the Assessor
to change her records to reflect the correct dimensions.
