Clackamas County Assessor v. Geary

CourtOregon Tax Court
DecidedSeptember 21, 2012
DocketTC-MD 120298D
StatusUnpublished

This text of Clackamas County Assessor v. Geary (Clackamas County Assessor v. Geary) 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
Clackamas County Assessor v. Geary, (Or. Super. Ct. 2012).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

CLACKAMAS COUNTY ASSESSOR, ) ) Plaintiff, ) TC-MD 120298D ) v. ) ) KEVIN GEARY, ) ) Defendant. ) DECISION

Plaintiff appeals the 2011-12 real market value of property identified as Account

05003823 (subject property). A telephone trial (uncontested) was held on July 26, 2012. Todd

Cooper (Cooper), Registered Appraiser, appeared and testified on behalf of Plaintiff.

Plaintiff’s Exhibits 1 through 7 were admitted without objection.

I. STATEMENT OF FACTS

The subject property is a farmhouse style single family home that sits on 1.47 acres of

land in Northeast Clackamas County. (Ptf’s Ex 1 at 4.) The home is 3,832 square feet with two

stories, six bedrooms, and two bathrooms. (Id.) The home “was originally constructed around

the turn of the century and has had several subsequent additions and remodels. The most recent

addition was a 960 square foot area added in 2005.” (Id.) Cooper testified that the subject

property has good access to highway and freeway systems, shopping centers, employment

centers, and recreational centers.

Cooper testified that on December 6, 2000, approximately 300 gallons of heating oil were

mistakenly pumped into the subject property’s basement through an abandoned fill pipe that had

once been connected to a heating oil storage tank. (Ptf’s Ex 6 at 3.) Cooper testified that the

Department of Environmental Quality (DEQ) report stated that the oil spill contaminated the soil

DECISION TC-MD 120298D 1 below and around the subject property’s basement floor. (Id.) Cooper testified that DEQ

approved contractor Foss Environmental performed a “phase I investigation” and “phase II

mitigation and clean-up” of the subject property. (Ptf’s Ex 1at 17.) Foss Environmental

completed Phase I on March 16, 2001, and Phase II on May 16, 2001. (Ptf’s Ex 6 at 3.) Cooper

testified that Foss Environmental’s “Remedial Investigation Report” dated July 2001, identified

“no impacts to nearby domestic well” and “no residual risk from heating oil constituents using a

risk-based analysis.” (Id.) After inspecting the subject property on June 11, 2002, “DEQ

determined that no further remedial action was required.” (Id.)

Plaintiff appeals the Board of Property Tax Appeals (BOPTA) Order, dated March 13,

2012, determining a real market value of $100,000. (Ptf’s Compl at 2.) According to the

BOPTA Order, the subject property’s maximum assessed value is $313,163. (Id.) Cooper

testified that Plaintiff is requesting a real market value of $367,189 as of January 1, 2011.

Cooper testified that during the BOPTA hearing on February 6, 2012, the owner of the

subject property testified that the subject property was stigmatized from the contamination that

occurred in December 2000. Cooper testified that the owner of the subject property did not

provide BOPTA with any evidence indicating that the property suffered from a long term stigma.

Cooper testified that as a result of the BOPTA hearing, BOPTA reduced the real market value of

the subject property from $367,189 to $100,000. (Ptf’s Compl at 2.)

Cooper testified that he performed market research “to determine if a negative adjustment

was appropriate due to [the] prior contamination.” (Ptf’s Ex 1 at 17.) Cooper testified that he

began his research with 30 previously contaminated properties, and then narrowed the sample to

the six properties most comparable to the subject property based on type and degree of

contamination. Cooper testified that he compared the six properties’ sale prices with their real

DECISION TC-MD 120298D 2 market values assigned by the county. Cooper testified that he found that all of the previously

contaminated properties sold for prices higher than the county’s real market tax roll values. (See

Ptf’s Ex 7 at 1.) Cooper testified that his “research indicated that once the contamination is

properly remediated (and certified by D.E.Q.) and given adequate seasoning time of 12-36

months with no further reported contamination, similarly contaminated properties have sold at or

very near market values and with marketing times typical of non-contaminated properties.”

(Ptf’s Ex 1 at 17.) Cooper testified that his research found no long term stigma attached to

previously contaminated properties that are comparable to the subject property.

Cooper testified that he considered the three valuation approaches in determining the

subject property’s 2011-12 real market value. (Ptf’s Ex 1 at 11.) Cooper testified that “[t]he

income approach was considered, but [was] not felt to be a credible indicator of market value as

homes in the subject area are generally acquired for owner occupied, single family use rather

than as income producing properties.” (Id.)

Cooper testified that “[t]he cost approach indicates a value for the subject property of

$367,189 as of 01/01/2011.” (Ptf’s Ex 1 at 11.) Cooper testified that “[t]he cost approach is the

basis for the original valuation of the subject property for tax assessment purposes for January 1,

2011 * * *.” (Id. at 17.) Cooper testified that the county’s original valuation of the subject

property supports a real market value of $367,189. (Ptf’s Compl at 2.) Cooper testified that he

included the $367,189 as the cost approach value in his appraisal report, but did not perform a

new cost approach valuation. Cooper testified that the cost “valuation approach is typically more

reliable with newly constructed homes * * * therefore the cost approach was given less weight in

the final reconciliation.” (Ptf’s Ex 1 at 11.)

///

DECISION TC-MD 120298D 3 Cooper testified that the sales comparison approach “supports a final estimate of value

for the subject property of $415,000 as of 01/01/2011.” (Ptf’s Ex 1 at 11.) Plaintiff submitted

the sale prices for five comparable properties as evidence of the subject property’s real market

value.1 (Ptf’s Ex 1 at 5.) The sale prices range from $317,500 to $465,000. (Id.) Cooper

testified that he adjusted each comparable property’s sale price to accurately reflect the

conditions of the subject property. The sale prices of Comparable # 2, # 3, # 4, and # 5 were

increased $81,300 (22.2 percent), $27,800 (7.5 percent), $32,540 (8.6 percent), and $76,040

(23.9 percent) respectively. (Id.) The sale price of Comparable # 1 was decreased $24,500

(5.3%). (Id.) The adjusted sale prices range from $393,540 to $447,800. (Id.)

The subject property is “located in an area that experienced a decline in property values

for the twelve months prior to the effective date of appraisal.” (Ptf’s Ex 1 at 15-16.) Cooper

made adjustments “based upon the estimated rate of decline of 8.0% over the prior twelve

months.” (Id. at 16.) Adjustments for differences in above grade finished living area and

differences in garage area were made at the rates of $40.00 per square foot and $10.00 per square

foot respectively. (Id.) Cooper increased the sale price of Comparable # 1 by $2,500, because

the property lacked central air conditioning. (Id.) Cooper decreased the sale prices of

Comparables # 1 and # 4 by $35,000 each, because the properties were remodeled and in better

condition than the subject property. (Id.) Cooper decreased the sale price of Comparable # 3 by

$15,000, because the property “included a small finished guest quarters area at the time of sale.”

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