Elkin v. Lincoln County Assessor

CourtOregon Tax Court
DecidedAugust 18, 2015
DocketTC-MD 150177N
StatusUnpublished

This text of Elkin v. Lincoln County Assessor (Elkin v. Lincoln 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
Elkin v. Lincoln County Assessor, (Or. Super. Ct. 2015).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

BRADLEY J. ELKIN ) and LORRAINE L. ELKIN, ) ) Plaintiffs, ) TC-MD 150177N ) v. ) ) LINCOLN COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION

This Final Decision incorporates without change the court’s Decision, entered July 31,

2015. The court did not receive a statement of costs and disbursements within 14 days after its

Decision was entered. See TCR-MD 16 C(1).

Plaintiffs appealed the real market value of property identified as Account R408329

(subject property) for the 2014-15 tax year. A trial was held on June 29, 2015, in the Oregon

Tax Courtroom in Salem, Oregon. Plaintiffs both appeared for trial. Bradley J. Elkin (Elkin)

testified on behalf of Plaintiffs. Craig Waldron (Waldron), appraiser, appeared and testified on

behalf of Defendant. Plaintiffs attached over 50 pages to their Complaint, including a broker’s

letter regarding the sale of the subject property, the listing history for the subject property, and an

inspection report for the subject property dated August 15, 2014. However, because Plaintiffs

failed to submit those documents as exhibits in accordance with the court’s exhibit exchange

rule, Tax Court Rule-Magistrate Division (TCR-MD) 12, they were not considered by the court.

Plaintiffs offered additional exhibits at trial on the cost to cure the subject property’s physical

deterioration. Defendant objected to those exhibits because they were not timely exchanged and

the court excluded them. Defendant’s Exhibits A through Q were received without objection.

///

FINAL DECISION TC-MD 150177N 1 I. STATEMENT OF FACTS

In his appraisal report, Waldron described the subject property as a 2,884-square-foot

house built in 1950 and situated on a 5,000-square-foot site. (Def’s Ex A.) Elkin testified that

the subject property is ocean front. He testified that the subject property’s prior owner

remodeled the upper level of the subject property in 1995, but did not remodel the first floor,

which is original to its 1950 construction. Elkin testified that the subject property included a

“nonconforming kitchen” on the second level. (See also Def’s Ex F at 1.) He testified that the

kitchen was added during the partial remodel of the subject property in 1995, but that it did not

meet county codes and would have to be removed.

Waldron testified that Defendant added value for the subject property’s second kitchen

because it existed as of the January 1, 2014, assessment date; he did not make any adjustment for

the fact that it was nonconforming. Waldron testified that the subject property’s upper level was

class 4+ and its lower level was class 3. His appraisal report described the subject property as

class 4+. (Def’s Ex A.)

The parties agreed that the subject property suffered some from some curable physical

deterioration as of the assessment date. Elkin testified that the subject property’s prior owner

lived in Hawaii and did not maintain the subject property. (See also Def’s Ex F at 1 (listing

stating “1 seller is a licensed agent in Hawaii”).) He testified that the subject property had some

dry rot under the deck siding and on the side of the house. Elkin testified that he obtained bids

for repairs totaling $49,500, not including removal of the nonconforming kitchen. He testified

that the necessary repairs included: adding insulation and sheetrock between the garage and first

floor; adding a fireproof door; repairing the chimney cap, skylight, furnace, anchor railing, and

stairs; replacing several windows; and completing some electrical work. Elkin testified that

FINAL DECISION TC-MD 150177N 2 repairing the dry rot and siding was the largest item, with an estimated cost of $22,000.

Waldron testified that he determined the subject property was “76 percent good.” He

testified that he estimated the cost to cure the subject property was approximately $42,300 based

on the difference between the subject property’s real market value at “76 percent good” and at

“100 percent good.”

Elkin testified that Plaintiffs purchased the subject property after selling their former

home, located directly across the street. He testified that the subject property had been on the

market for 17 months. Plaintiffs purchased the subject property for $425,000 in September

2014. (Compl at 3; See Def’s Ex C at 1.) Elkin testified that Plaintiffs were aware the subject

property needed substantial repairs at the time they purchased it. He testified that Plaintiffs

received a home inspection report detailing the subject property’s physical deterioration.

Waldron testified that the sale of the subject property was a “good sale” and that

Defendant had confirmed the sale. He testified that one sale does not make the market and that

he found the subject property sale to be out of line with other market evidence. Waldron testified

that he thought the subject property’s sale price might have been low because of its physical

deterioration and because Plaintiffs paid all cash. Elkin testified that Plaintiffs had to pay all

cash because, given the subject property’s physical deterioration and code violations, no bank

would have financed the sale.

Waldron testified that he used a “market-related cost approach” to determine the subject

property’s 2014-15 real market value. He testified that a “market-related cost approach” relies

on comparable sales adjusted using cost factors. Waldron testified that he tried to identify sales

of oceanfront properties similar in age and class to the subject property. He testified that he only

used arm’s-length sales.

FINAL DECISION TC-MD 150177N 3 Waldron testified that he identified four comparable oceanfront properties that sold close

to the January 1, 2014, assessment date. (See Def’s Ex A.) The sales occurred between April

and December 2014. (Id.) Waldron did not make any time adjustments. (See id.) The site sizes

of the four comparable sales ranged from 3,200 to 4,500 square feet, while the subject property’s

subject property’s site was 5,000 square feet. (Id.) Waldron made upward site adjustments

ranging from $9,520 to $70,613. (Id.) He testified that the site adjustments were based on

Defendant’s 1993 and 1994 “land base” studies, which were trended to 2014. (See Def’s Ex P,

Q.1) He made upward “view” adjustments ranging from $7,000 to $28,245 to three of his sales.

(Def’s Ex A.)

Waldron’s four sales were built between 1938 and 1979. (Def’s Ex A.) They ranged in

size from 999 to 1,508 square feet of gross living area, whereas the subject property had 2,884

square feet of gross living area. (Id.) Waldron testified that he made “gross living value”

adjustments to his sales that reflected differences in size, class, and quality. (See id.) He

testified that those adjustments were based on the Oregon Department of Revenue’s 1993 Cost

Factor Book. Waldron’s “gross living value” adjustments were all upward and ranged from

$82,140 to $107,550. (Id.) Each of his net adjustments was upward; they ranged from 23.2

percent to 48.2 percent of the unadjusted sale price. (See id.)

Waldron testified that he placed equal weight on all four of his comparable sales, and that

he determined an indicated real market value for the subject property based on the average of the

adjusted prices for the four sales. He testified that he concluded a real market value of $540,000

for the subject property. (See Def’s Ex A.)

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Elkin v. Lincoln County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elkin-v-lincoln-county-assessor-ortc-2015.