Aragones v. Multnomah County Assessor

CourtOregon Tax Court
DecidedSeptember 13, 2023
DocketTC-MD 220072N
StatusUnpublished

This text of Aragones v. Multnomah County Assessor (Aragones v. Multnomah County Assessor) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aragones v. Multnomah County Assessor, (Or. Super. Ct. 2023).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

LILIO ARAGONES, ) ) Plaintiff, ) TC-MD 220072N ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appealed the assessment of property identified as Account R198338 (subject

property) for the 2019-20, 2020-21, and 2021-22 tax years. A trial was held by remote means on

April 19, 2023. Steve Anderson (Anderson), registered appraiser, appeared and testified on

behalf of Plaintiff. Scott Elliott and John James appeared on behalf of Defendant. Shane Turner

(Turner), registered appraiser, testified on behalf of Defendant. Plaintiff’s Exhibit 1 and Rebuttal

Exhibit 1, and Defendant’s Exhibit A, were received without objection.

I. STATEMENT OF FACTS

The subject property is a two-story “daylight ranch style” house built in 1963 and situated

on an 8,700-square foot, or 0.2-acre, lot in Northwest Portland. (Ptf’s Ex 1 at 1; see also Def’s

Ex A at 3-6.) It includes an attached two-car garage. (Id.) The house is 2,358 square feet, of

which the main level is 1,253 square feet and the below-grade daylight basement is 1,105 square

feet. (Ptf’s Ex 1 at 14; Def’s Ex A at 3.) The house includes three bedrooms, two full

bathrooms, and one half-bathroom. (Id.) Anderson testified that the house’s condition was

“average” or “average minus,” with some original elements including the downstairs bathroom

and kitchen cabinets, and extremely steep stairs to the lower level. He did not consider the house

to be a “fixer” or to suffer from deferred maintenance but noted that many upgrades would be

required to effectively market the subject property. Turner determined the house was “average”

DECISION TC-MD 220072N 1 or “average plus” condition.1 (See Def’s Ex A at 3.) He noted some higher quality features

including hardwood floors, granite countertops, and bathroom tilework. (See id.) Anderson

testified that the subject property site is “extremely steep” with no yard, but it has a view of

downtown Portland. (Ptf’s Ex 1 at 1.)

Both appraisers relied solely upon the sales comparison approach to determine the subject

property’s value. Anderson testified that he drove by all his comparable sales, but he did not

attempt to confirm any of them. Turner testified that he attempted to confirm his comparable

sales by sending emails to the realtors involved, but he did not receive responses to all emails.

He gave less weight to sales that he could not confirm. Anderson and Turner selected several of

the same sales as comparable to the subject property. (See Ptf’s Ex 1 at 14, 22-23, 37-38; Def’s

Ex A at 3-5.)

Anderson testified that all his comparable sales were within 16 blocks of the subject

property.2 For the 2019-20 tax year, he selected three comparable sales that ranged from

$749,000 to $850,000. (Ptf’s Ex 1 at 14.) After adjustments, the sales indicated a range of

$553,400 to $723,400, and he concluded a value of $590,000 for the 2019-20 tax year. (Id. at 2,

14.) For the 2020-21 tax year, Anderson selected six comparable sales that ranged from

$502,765 to $755,000. (Id. at 22-23.) After adjustments, the sales indicated a range of $553,400

to $720,800, and he concluded a value of $660,000 for the 2020-21 tax year. (Id. at 2, 22-23.)

For the 2021-22 tax year, Anderson selected six comparable sales that ranged from $502,765 to

$840,000. (Id. at 37-38.) After adjustments, the sales indicated a range of $644,965 to $766,400

and he concluded a value of $650,000 for the 2021-22 tax year. (Id. at 2, 37-38.)

1 The sales grid lists the subject property as “average” but the accompanying narrative states “AVG+.” (Def’s Ex A at 3.) 2 Additional details about the comparable sales are discussed in the analysis to the extent relevant.

DECISION TC-MD 220072N 2 Anderson’s sales grids reflect adjustments for differences in the site, bathrooms, garage,

living area, and time of sale.3 (Ptf’s Ex 1 at 14, 22-23, 37-38.) He testified that his site

adjustments also reflected differences in view, topography, and market conditions. Anderson’s

adjustment for living area was a combined adjustment based on $90 per square foot for the main

floor and $50 per square foot for the lower level. In selecting a value from the range for each tax

year, Anderson testified that he relied upon his experience and judgment.

Turner testified that, for each tax year at issue, he considered six or seven sales, but

ultimately selected the three most comparable sales to the subject property for each year.4 For

the 2019-20 tax year, Turner’s three sales ranged from $600,000 to $780,000. (Def’s Ex A at 3.)

After adjustments, the sales ranged from $622,000 to $784,000, and he concluded a value of

$750,000. (Id.) For the 2020-21 tax year, Turner’s three sales ranged from $755,000 to

$813,000. (Id. at 4.) After adjustments, they ranged from $728,000 to $788,000, and he

concluded a value of $755,000. (Id.) For the 2021-22 tax year, Turner’s sales ranged from

$750,000 to $755,000. (Id. at 5.) After adjustments, they ranged from $746,000 to $781,000,

and he concluded a value of $755,000. (Id.)

Turner’s sales grids reflect adjustments for sale date, view, quality, number of rooms,

above-grade living area, below-grade living area, heating and air conditioning, garage, and

outdoor features such as decks and patios. (Def’s Ex A at 3-5.) Turner testified that he did not

adjust for excess land or age because he could not determine market-based adjustments, but he

took those characteristics into account in weighing the sales. He found an upward market trend

of 1.69 percent in 2019, 3.89 percent in 2020, and 5.22 percent in 2021.

3 Anderson testified that he did not make any time adjustments for the 2019-20 tax year because the market was stable. 4 Additional details about the comparable sales are discussed in the analysis section to the extent relevant.

DECISION TC-MD 220072N 3 The parties’ value opinions for each year are set forth below and compared to the tax roll:

2019-20 2020-21 2021-22 Plaintiff $590,000 $660,000 $650,000 Defendant $750,000 $755,000 $755,000 Tax Roll $827,250 $827,250 $869,750

II. ANALYSIS

The issues before the court are the subject property’s 2019-20, 2020-21, and 2021-22 real

market values. “Real market value” is “the amount in cash that could reasonably be expected to

be paid by an informed buyer to an informed seller, each acting without compulsion in an arm’s-

length transaction occurring as of the assessment date for the tax year.” ORS 308.205(1).5 The

assessment date was January 1, 2019, for the 2019-20 tax year; January 1, 2020, for the 2020-21

tax year; and January 1, 2021, for the 2021-22 tax year. ORS 308.007; ORS 308.210. Real

market value “shall be determined by methods and procedures in accordance with rules adopted

by the Department of Revenue * * *.” ORS 308.205(2). Three approaches to value must be

considered but may not be applicable in every case: the cost approach; the sales comparison

approach; and the income approach. OAR 150-308-0240(2)(a).

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Aragones v. Multnomah County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aragones-v-multnomah-county-assessor-ortc-2023.