Board Finds Petitioner's Comparable Sale Evidence Fails to Support a Lower Property Value

Here, the Trust relied primarily on sales information forproperties located in the subject property’s neighborhood. Of course, saleprices for other properties do not, by themselves, show the value of a givenproperty. But when one analyzes those sales prices using generally acceptedappraisal principles, such as the sales-comparison approach, that raw data canbe transformed into a reliable value indicator. See generally, MANUAL at13-14 (describing the sales-comparison approach).
In order to effectively use a sales-comparison approach asevidence in an assessment appeal, one must first show that the properties beingexamined are comparable to each other. Conclusory statements that a property is“similar” or “comparable” to another property are not probative of theproperties’ comparability. Long v. Wayne Twp. Assessor, 821 N.E.2d 466,470-471 (Ind. Tax Ct. 2005). Instead, one must identify the characteristics ofthe property under appeal and explain how those characteristics compare to thecharacteristics of the purportedly comparable properties. Similarly, one mustexplain how any differences between the properties affect their relative marketvalues-in-use. Id.
The Trust did not offer the type of analysis contemplated bythe Indiana Tax Court in Long. At most, Mr. Robinson testified that twoof the homes are bigger than the subject home, and that all three are newer.But as the Assessor explained, Mr. Robinson ignored other relevantcharacteristics, including relevant differences between the properties incondition, lot size, and amenities.
Even if the Trust had offered a more reasoned analysis of itspurportedly comparable sales, only one sale bears any relationship to the March1, 2010 valuation date—the second sale of 11028 North Landings Road. Theremaining sales occurred between 21 and 34 months before March 1, 2010. Mr.Robinson, however, did not even attempt to explain how the sale prices from2007 and 2008 relate to the subject property’s market value-in-use as of March1, 2010.
The Trust also claimed that the Assessor erred in assessingthe subject home for a basement when it really sits on a crawl space. But asthe Assessor pointed out, the Trust did not raise that issue in front of thePTABOA or even on its Form 131 petition to the Board. Although the Assessor didnot use the word “objection,” the record shows that she did not consent to trythat issue. Given the lack of notice to the Assessor, the issue of whether thehome is incorrectly assessed as having a basement is not before the Board.Nonetheless, in light of the Assessor’s agreement to do so, the Board ordersher to inspect the property to determine if it has a basement or crawl spaceand to make corrections if appropriate.
http://www.in.gov/ibtr/files/Richard_Robinson_Irrev_Family_Trust_08-011-10-1-5-00007.pdf