Clunes v. Clackamas County Assessor

CourtOregon Tax Court
DecidedNovember 14, 2012
DocketTC-MD 120255C
StatusUnpublished

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

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

CHERYLE CLUNES, ) ) Plaintiff, ) TC-MD 120255C ) v. ) ) CLACKAMAS COUNTY ASSESSOR, ) ) Defendant. ) DECISION

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

01415828 (subject property) for the 2011-12 tax year. Trial for the matter was held on

September 25, 2012, by telephone. Steven Anderson (Anderson), an Oregon licensed real estate

broker, appeared on behalf of Plaintiff.1 Todd Cooper (Cooper) appeared on behalf of

Defendant. Plaintiff’s Exhibits 1 through 8 and Defendant’s Exhibits A and B were admitted

without objection.

I. STATEMENT OF FACTS

The appeal involves the RMV of a single-family residential home for the 2011-12 tax

year. The RMV on the assessment and tax rolls, as reduced by the Clackamas County Board of

Property Tax Appeals (BOPTA), is $398,000. The assessment date is January 1, 2011.

ORS 308.007; ORS 308.210.2

The subject property is a 3,794 square-foot, two-story, three-level home built in 1990 and

situated on a 9,265 square-foot lot in Clackamas, Oregon. (Def’s Ex A at 4.) The home has

three bedrooms, two full bathrooms, and two half bathrooms. (Id.) There is also a four or five

car attached garage. (Id.) Exterior amenities include a 50 year comp roof, lap siding with brick 1 Plaintiff’s Authorization to Represent. (Ptf’s Compl at 2.) 2 All references to the Oregon Revised Statutes (ORS) and Oregon Administrative Rules (OAR) are to 2009.

DECISION TC-MD 120255C 1 accents, a wood deck, and full landscaping. (Id.) Interior amenities include hardwood and

carpeted floors, granite kitchen counters, brick fireplaces, and high-end appliances. (Id.) The

subject property enjoys views of both Mount Hood and the valley to the east of the home. (Id.)

Defendant set the RMV at $459,832, with $115,442 allocated to the land and $344,090 to

the structures (i.e., the home and other real property improvements). (Ptf’s Compl at 3.) The

maximum assessed value (MAV) is $451,653, as is the assessed value (AV). (Id.) Plaintiff

successfully appealed to the Clackamas County Board of Property Tax Appeals (Board) and the

Board reduced the RMV of the structures to $282,558, for a total RMV of $398,000. (Id.)

Because that member is less than the property’s MAV, the AV was reduced to $398,000,

pursuant to ORS 308.146(2). (Id.)

A. Plaintiff’s value evidence

Plaintiff’s presentation was very brief, consisting of a summary overview of Anderson’s

comparable sales approach and his valuation grid. (Ptf’s Ex 3 at 3.) On cross examination,

Anderson described the grid as a “price opinion” based on 24 years of market experience,

including four years as a BOPTA board member and 22.5 hours of training from the Oregon

Department of Revenue.

Plaintiff presented three comparable sales, two of which occurred prior to the assessment

date and the third, 11 months after the assessment date.3 (Ptf’s Ex 3 at 3) Comparable one sold

on November 15, 2011, at an unadjusted sale price of $305,000; comparable two sold on March

26, 2010, at an unadjusted sale price of $375,000; comparable three sold on June 29, 2011, at an

unadjusted sale price of $394,000. (Id.)

Anderson adjusted for differences in exterior, number of fireplaces, square footage (of

both the home and the garage), quality, and time. (Id.) For example, Anderson made a $20,000

3 Defendant also used these same comparables in its valuation grid.

DECISION TC-MD 120255C 2 negative adjustment to comparable one for its new kitchen, testifying that he felt it was superior

to that of the subject property. (See id.) Defendant took exception to the $20,000 adjustment,

noting that there is insufficient detail of the nature and extent of the kitchen remodel in

comparable one and that the subject property itself had an upscale kitchen.

Anderson’s valuation grid sheet shows adjusted sale prices of comparables one through

three of $333,650, $356,525, and $344,750, respectively. (Id.) However, Andersen

acknowledged on cross-examination that he made adjustment errors for the basements of

comparables one and two, adjusting them up $35 per square-foot whereas the adjustment should

have been a downward adjustment of $16,100 each. He also acknowledged that he made a time

adjustment error with respect to comparable one; the net effect of that mistake resulted in a

$33,550 increase to its sale price. Anderson’s final, trial adjusted sale prices for comparables

one through three are $383,300, $372,625, and $344,750, respectively. Anderson testified that

he gave most weight to comparable three, although he considers it superior to the subject

property. Plaintiff’s Complaint requests a reduction in RMV to $300,000. At trial, Anderson

modified Plaintiff’s request, seeking an RMV of $350,000.

B. Defendant’s value evidence

Cooper’s presentation focused on the sales comparison approach and, like Plaintiff,

presented a valuation grid (titled “Comparable Sales Grid”). (Def’s Ex A at 5.) Cooper gave

little weight to the cost approach because the “home was over 20 years old as of the assessment

date”; 4 the income approach was considered but Copper concluded that it was not “a credible

indicator of market value * * *.” (Id. at 16.)

///

4 Cooper concluded that “[t]he cost approach indicates a value for the subject property of $399,012 ” as of the assessment date. (Def’s Ex A at 16.)

DECISION TC-MD 120255C 3 Cooper’s valuation grid shows six comparable sales with the following information:

comparable one (which is also Plaintiff’s comparable three) sold on June 24, 2010, at an

unadjusted sale price of $390,000; comparable two sold on February 23, 2011, at an unadjusted

sale price of $317,000; comparable three sold on November 12, 2010, at an unadjusted sale price

of $300,000; comparable four sold on November 15, 2011, at an unadjusted sale price of

$305,000; comparable five sold on June 18, 2010, at an unadjusted sale price of $390,000;

comparable six sold on March 26, 2010, at an unadjusted sales price of $375,000. (Id. at 5.)

Cooper made adjustments for time, overall quality, size (for square footage differences

above grade, in basement space, and in garage size), bathrooms, view, and heating/cooling

source. (Id.) For example, because comparables two, three, and six lacked an appealing view,

their sale prices were adjusted upward $32,300 each, a “market derived” adjustment. (Id.) Also,

the sale prices of comparables one and six were adjusted downward $33,100 each because of

their superior quality; comparables three and four have inferior quality, and their sales prices

were adjusted upward $33,100 each. (Id. at 9.) Cooper admitted on cross examination that he

did not make time adjustments accurate to the day, stating that such adjustments would result in

only minor changes to his adjusted sale prices. Cooper stated that all “adjustments were derived

from the market using paired sales analysis and extraction techniques and are supported by the

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Clunes v. Clackamas County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clunes-v-clackamas-county-assessor-ortc-2012.