Crawford v. Douglas County Assessor

CourtOregon Tax Court
DecidedMarch 17, 2014
DocketTC-MD 130462C
StatusUnpublished

This text of Crawford v. Douglas County Assessor (Crawford v. Douglas 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
Crawford v. Douglas County Assessor, (Or. Super. Ct. 2014).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

RALPH L. CRAWFORD, ) ) Plaintiff, ) TC-MD 130462C ) v. ) ) DOUGLAS COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION OF DISMISSAL

The court entered its Decision of Dismissal in the above-entitled matter on February 19,

2014. The court did not receive a request for an award of costs and disbursements (TCR-MD 19)

within 14 days after its Decision of Dismissal was entered. The court’s Final Decision of

Dismissal incorporates its Decision of Dismissal without change.

Plaintiff appealed Defendant’s omitted property assessment for tax years 2007-08

through 2012-13, issued June 14, 2013. Trial was held by telephone December 14, 2013.

Plaintiff appeared on his own behalf. Defendant was represented by Paul Meyer, Assistant

County Counsel, Douglas County. Plaintiff’s Exhibits 1, 3 through 6, 8 through 16, 18, 19, 23,

24, and 30, were admitted at trial without objection. Defendant did not present any witnesses to

testify at trial but did submit rebuttal Exhibit B during its cross-examination of Plaintiff.

I. STATEMENT OF FACTS

According to the testimony and certain exhibits, the subject property consists of a small

house approximately 750 to 800 square feet in size, and two other structures (approximately 315

square feet and 450 square feet), on five acres of land located in a remote area in the small town

///

FINAL DECISION OF DISMISSAL TC-MD 130462C 1 of Dillard, Oregon, in close proximity to a rock quarry.1 (Ptf’s Exs 1, 18, 19.) The property is

identified in Defendant’s records as Account R44324. (Ptf’s Compl at 1, 3.)

Defendant discovered Plaintiff made improvements to the property going back to 2001

and added omitted property to the assessment and tax rolls for tax years 2007-08 through

2012-13. (Id. at 3.) The value was added June 14, 2013. (Id.) The omitted property notice

Plaintiff submitted with his Complaint lists only the new, changed assessed values, not the

increases in real market value.2 Defendant stated during its opening that the real market value

for tax year 2007-08, after the addition of omitted property, was $157,468, and that the value of

the property added (referred to as “exception value”), was $42,843. Plaintiff did not dispute

those figures. The 2007-08 tax year is the first of the six years for which omitted property was

added to the rolls and Defendant began by determining the value for that year and then adjusting

the value for subsequent years based on trending from its annual ratio studies.

Defendant’s omitted property assessment notice submitted by Plaintiff provides the

following reason for the changes in value: “[h]ouse I2 was remodeled & added on to; previous

value was $500 on the building, is now a class 2 house w/finished attic area, also added a general

purpose shed, concrete, lean-to & small deck. There are two other houses on the property & due

to condition were valued at $500 each. The homesite was also adjusted for lack of water &

location (negative adj) and additional utilities & creek influence (positive adj).” (Id.)

1 Plaintiff's Exhibit 19 is a rudimentary sketch of Plaintiff's home after the remodel that Plaintiff testified was prepared by two individuals, one of whom is a former employee of the Douglas County Assessor’s office. That document indicates that the square footage of the home is 754.5 square feet, that there is a 457.4 square foot yellow storage building, and a 314.6 square foot red storage building. Defendant disputed those measurements on cross-examination, suggesting the main house was closer to 830 square feet if properly measured. In the end, the court need not know the precise size of the home and outbuildings to render its decision. 2 The notice Plaintiff appealed from is Defendant’s notice of the correction to the rolls that added the omitted property value and increased the taxes. (Ptf’s Compl at 3.) It is dated June 14, 2013. Plaintiff did not submit the notice of intent to add omitted property that the county sends pursuant to ORS 311.216 and ORS 311.219. That notice often includes more detailed information including the amount of real market value being added to the account for the omitted property, and the new maximum assessed and assessed values.

FINAL DECISION OF DISMISSAL TC-MD 130462C 2 Plaintiff asserts in his Complaint that: 1) Defendant’s omitted property assessment is in

error because the remodel work he did to the subject property constituted “minor construction”

and therefore could not be added to the rolls as omitted property; 2) Defendant has misclassified

some of his property; 3) some of the structures Defendant added as omitted property existed

before Plaintiff’s 1999 purchase and cannot be added as omitted property; 4) Defendant has

incorrectly measured some of his buildings; 5) Defendant has incorrectly identified the number

of dwellings on the property, allegedly treating the two other houses that Plaintiff purportedly

decommissioned by removing the kitchen and bathroom as dwellings when, in fact, they are no

more than storage sheds or outbuildings; 6) Defendant added omitted property for years it had no

authority to adjust by omit assessment, and 7) Defendant overvalued his land. (Ptf’s Compl

at 2.)

According to Plaintiff’s testimony, he bought the subject property in 1999 for

approximately $68,000. Plaintiff testified that between 2001 and December 2005 he did some

work on the property, decommissioning two of the three existing structures and remodeling the

third structure, turning it into his home. Plaintiff testified that, between 2001 and 2005, he lived

in one of the two now decommissioned buildings (referred to by Plaintiff as “the yellow house”)

while he worked on the home he remodeled and now lives in (referred to by the parties as “I2”).

Defendant questioned Plaintiff on cross-examination about the “yellow house,” and in line with

that questioning referred to Rebuttal Exhibit B at 6. That exhibit is a picture of the yellow house

and shows smoke coming out of the chimney. Plaintiff was asked during cross-examination to

explain why there was smoke coming out of the chimney and why there was a vehicle parked

outside the building and a dog inside barking at the time an appraiser from the assessor’s office

FINAL DECISION OF DISMISSAL TC-MD 130462C 3 made a site visit to the subject property. In response, Plaintiff testified that he and his son

occasionally go over to that building to “run the stove.”

Plaintiff presented a summary of his alleged building material costs, which he testified

was based on entries in his checkbook register. Plaintiff also submitted a few bank statements

and some receipts for building materials. (Ptf’s Exs 7, 8.) Plaintiff testified that his total costs

for building materials were $8,984.28. (Ptf’s Ex 9.)

Plaintiff’s Exhibit 10 is an estimate of his labor costs because Plaintiff testified that he

did the majority of the work himself. Plaintiff presented an estimate of the number of hours he

spent working on the property between 2001 and 2005 based on calculations he had made for a

previous trial in this court in 2010, five years after the work was completed. Plaintiff estimated

that he spent 580 hours working on the home, and he estimated the value of his labor at $10 per

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Crawford v. Douglas County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crawford-v-douglas-county-assessor-ortc-2014.