Big Moose Development Inc. v. Multnomah County Assessor

CourtOregon Tax Court
DecidedJanuary 11, 2013
DocketTC-MD 120251C
StatusUnpublished

This text of Big Moose Development Inc. v. Multnomah County Assessor (Big Moose Development Inc. 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
Big Moose Development Inc. v. Multnomah County Assessor, (Or. Super. Ct. 2013).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

BIG MOOSE DEVELOPMENT INC., ) ) Plaintiff, ) TC-MD 120251C ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff has appealed the real market value (RMV) of property identified as Account

R172807 (subject property), for the 2011-12 tax year. Trial in the matter was held by telephone

December 5, 2012. Plaintiff was represented by Steven Anderson (Anderson), Oregon Licensed

Real Estate Broker, with 24 years of experience in real estate. Defendant was represented by Jeff

Sanders (Sanders), Oregon Registered Appraiser III, and Jeff Brown (Brown), Residential

Appeals Lead Appraiser, Multnomah County Assessor‟s office. Sanders, who prepared the

appraisal report for Defendant, began his appraisal career as a residential fee appraiser in the late

1990s, then appraised property for the Washington County Assessor‟s office between 2000 and

2006, before moving to the Multnomah County Assessor's office in 2006. Plaintiff‟s exhibits 1

and 2 and Defendant‟s exhibit A were admitted into evidence at trial.

I. STATEMENT OF FACTS

The subject property is a 4,857 square foot single-family residential home with five

bedrooms and either three or four bathrooms.1 (Ptf‟s Ex 1-1; Def‟s Ex A at 3.) The home sits on

a nearly one-third acre lot (12,900 square feet). (Ptf‟s Ex 1-1; Def‟s Ex A at 3.) Other amenities

include a gourmet kitchen, wood floors in the kitchen, dining room, and living room, a master

bedroom with a private balcony, “extensive woodwork,” open beam and vaulted ceilings, and

1 Anderson submitted the listing document for the subject property and it indicates that the home has three bathrooms. Sanders‟ appraisal report, however, indicates that the subject has four full baths. (Def's Ex A at 3, 7; Ptf‟s Ex 1-1.)

DECISION TC-MD 120251C 1 four fireplaces. (Ptf‟s Ex 1-1.) The home is located in close proximity to downtown Portland in

a desirable neighborhood known as Portland Heights/Green Hills. (Ptf‟s Ex 1-1, Def‟s Ex A at

3.)2 Anderson testified that the home was in Southwest Portland, built in 1939, and is of average

quality.

Plaintiff purchased the property for $357,500 on or about October 7, 2011, which is

roughly 10 months after the applicable assessment date in this case.3 (Ptf‟s Ex 2-1.) Plaintiff

purchased the property after the home was foreclosed on by the lender. Plaintiff‟s representative

Anderson was unsure of the date when the lender acquired the property, but Brown, who

represented Defendant, testified that the deed indicated the lender‟s acquisition through

foreclosure was on June 9, 2010, “for $900,000.” Anderson objected to the testimony, arguing

that the deed was not submitted into evidence. The court overruled the objection, after asking

Anderson whether he had explored the details of the foreclosure, to which Anderson responded

he had not. However, Anderson acknowledged that he had no information to the contrary. The

court further noted that Anderson had ample opportunity to apprise himself of the foreclosure

information, given that Anderson was relying on Plaintiff‟s purchase from the bank, and that

Defendant‟s value report indicates that Plaintiff purchased the property in October 2011 “as a

bank owned property.” (Def‟s Ex A at 3.)

The RMV on the assessment and tax rolls for the 2011-12 tax year is $688,120, with

$222,000 allocated to the land and $466,120 to the structures (the home). (Ptf‟s Compl at 3.)

The property‟s maximum assessed value (MAV) is $611,840. Because that number is less than

the RMV currently on the assessment and tax rolls for the 2011-12 tax year, the assessed value

2 At trial, Sanders amended the neighborhood description set forth in his appraisal report. Anderson did not dispute the amended description of the neighborhood and the listing Anderson submitted indicates that the subject is in the Green Hills subdivision. 3 Anderson testified, and a written narrative submitted with his exhibits also states, that the date of sale was October 24, 2011. The date on the RMLS listing history, Plaintiff‟s Exhibit 2-1, indicates that the property sold October 7, 2011. The court finds the difference of 17 days to be of no consequence.

DECISION TC-MD 120251C 2 (AV) is the lesser $611,840, as required by statute. See generally ORS 308.146(2) (providing for

an AV that is the lesser of a property‟s RMV or MAV, except in certain limited statutorily

enumerated circumstances).

Plaintiff appealed the assessor‟s values to the Multnomah County Board of Property Tax

Appeals (Board) and the Board sustained the values. Plaintiff timely appealed the Board‟s

decision to this court, requesting a reduction in the RMV to $357,500 based on Plaintiff‟s

purchase of the property for that amount in October 2011. Defendant submitted an appraisal

report concluding with an opinion of value (RMV) of $825,000, and at trial requested that the

court increase the RMV to that figure in accordance with the authority given the court under

ORS 305.412 (2011).

II. ANALYSIS

A. Valuation and burden of proof – laws, rules, and accepted procedures

In Oregon, all real property “not exempt from ad valorem property taxation or subject to

special assessment shall be valued at 100 percent of its real market value.” ORS 308.232. 4

RMV is defined in ORS 308.205(1) as follows:

“Real market value of all property, real and personal, means 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.”

For purposes of property assessment and taxation, RMV is determined by the particular

methods and procedures adopted by the Department of Revenue. ORS 308.205(2). There are

three approaches to valuation (income, cost, and sales comparison) that must be considered when

determining the RMV of a property, although they need not all be developed. OAR 150-

308.205-(A)(2)(a) (stating that all three approaches must be considered, although all three

approaches may not be applicable to the valuation of a given property); see also Allen v. Dept. of 4 Unless noted otherwise, the court‟s references to the Oregon Revised Statute (ORS) are to 2009, references to the Oregon Administrative Rules (OAR) are to the current version.

DECISION TC-MD 120251C 3 Rev., 17 OTR 248, 252 (2003); Gangle v. Dept. of Rev., 13 OTR 343, 345 (1995); Appraisal

Institute, The Appraisal of Real Estate 130 (13th ed 2008). When value is appealed to the court,

the approach to be used (or combination of approaches) is a question of fact to be determined by

the court upon the record. Pacific Power & Light Co. v. Dept. of Rev., 286 Or 529, 533, 596 P2d

912 (1979) (“[W]hether in any given assessment one [valuation] approach should be used

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Reed v. Department of Revenue
798 P.2d 235 (Oregon Supreme Court, 1990)
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