Koch Inc. v. Malheur County Assessor

CourtOregon Tax Court
DecidedMarch 16, 2012
DocketTC-MD 110508N
StatusUnpublished

This text of Koch Inc. v. Malheur County Assessor (Koch Inc. v. Malheur 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
Koch Inc. v. Malheur County Assessor, (Or. Super. Ct. 2012).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

KOCH INC., ) ) Plaintiff, ) TC-MD 110508N ) v. ) ) MALHEUR COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appeals the real market value of property identified as Account 2360 (subject

property) for the 2010-11 tax year. A telephone trial was held in this matter on December 6,

2011. Glenn Koch (Glenn) appeared and testified on behalf of Plaintiff. Jonathan Koch (Jon)

also testified on behalf of Plaintiff.1 Chris Russell (Russell), Appraiser, appeared and testified on

behalf of Defendant. Richard Thurmond (Thurmond), Chief Appraiser, observed the trial.

Plaintiff’s Exhibits 1 through 16 were offered and received without objection. Defendant offered

Exhibits A through D; Plaintiff objected to Defendant’s Exhibit C because Plaintiff previously

requested in its motion for discovery (motion) any information about other sales, and Defendant

did not provide to Plaintiff the sales included in Exhibit C prior to exhibit change.

The information provided in Exhibit C was timely exchanged under Tax Court Rule-

Magistrate Division (TCR-MD) 10 C, but Glen argues that it should have been provided sooner

in response to Plaintiff’s motion. On July 7, 2011, Plaintiff filed its motion requesting:

“1. Either a written or taped copy of the minutes or the [M]arch 3, 2011 hearing of Koch Inc. before Malheur County Board of Property Tax Appeals.

“2. A copy of any new information the Defendants will be presenting in the hearing with Koch Inc. before the Oregon Tax Court.”

1 When referring to a party in a written decision, it is customary for the court to use the last name. However, in this case, the court’s Decision recites facts and references to two individuals with the same last name, Koch. To avoid confusion, the court will use the first name of the individual being referenced.

DECISION TC-MD 110508N 1 The parties discussed Plaintiff’s motion during the case management conference held in this

matter on October 10, 2011. During that conference, Defendant agreed to provide, and did

provide, Plaintiff with a copy of the tape from Plaintiff’s hearing before the Board of Property

Tax Appeals (BOPTA); Defendant also provided a certified transcript of the BOPTA hearing.

(See Def’s Ex A, B.) Defendant agreed to provide the information requested by Plaintiff and no

formal discovery order was issued in this case. With respect to the sales identified in

Defendant’s Exhibit C, Russell stated that he did not have the information any sooner than he

sent it to Plaintiff because it was research that he completed in preparation for trial.2 Russell

further noted that he complied with the exchange deadline in TCR-MD 10 C, as discussed during

the case management conference held in this matter. The court admitted Defendant’s Exhibit C

over Plaintiff’s objection because it was timely exchanged under TCR-MD 10 C.

I. STATEMENT OF FACTS

The subject property is a “medical office” located in Ontario, Oregon, on a 16,450

square-foot lot with a 2,496 square-foot improvement.3 (Def’s Ex 2C.) The subject property

was previously a “7-Eleven store.” (Def’s Ex A-3, 1C.) Jon testified that it is now used by nurse

practitioners. Plaintiff purchased the subject property in May 2002, for $125,000, and

subsequently remodeled it at a reported cost of $41,000. (Def’s Ex A-3.) Jon testified that he

completed the remodel work, which he described as “nice,” but not “fancy.”

///

2 It is noteworthy that Plaintiff did not contend that the information in Defendant’s Exhibit C was unavailable to Plaintiff prior to trial; by contrast, it appears to be publically-available information with the possible exception of Russell’s specific adjustments in his comparable sales analysis. 3 Defendant’s Exhibit 2C states the subject property “year built” as 1983. However, the BOPTA hearing transcript includes a description of the subject property by Jon as “40 years old.” (See Def’s Ex A-3.) It is unclear whether the subject property was built in 1983 or whether that is the effective age determined by Russell.

DECISION TC-MD 110508N 2 The 2010-11 real market value of the subject property set by Defendant and sustained by

BOPTA is $248,550. (Def’s Ex 2C; Ptf’s Compl at 6.) Thurmond stated that the subject

property’s 2010-11 maximum assessed value was $294,993, which is unchanged from the

2004-05 tax year. He explained that, because the subject property’s real market value has been

less than the maximum assessed value for each tax year since the 2004-05 tax year, the real

market value has been the assessed value each year, and the maximum assessed value has not

increased during that period of time. Plaintiff requested a 2010-11 real market value of

$162,320, which was the previously adjudicated value for the 2004-05 tax year. (See Ptf’s

Compl at 1.) Russell testified that the 2010-11 tax year is the first tax year for which the real

market value of the subject property is not the adjudicated value. He testified that Defendant is

required by law to determine real market value based on market evidence.

Glenn testified that he did not learn of the concept of maximum assessed value until

meeting with Defendant’s representatives on November 22, 2011, to discuss the possibility of

settling this appeal. He testified that, based on his conversation with Defendant’s

representatives, he was left with the understanding that “true cash value” is irrelevant to

“assessed values.” Glenn testified that, despite the irrelevance of “true cash value” to “assessed

value,” it appears to him that Defendant is still interested in “true cash value” based on

Defendant’s “Request for Review of True Cash Value of Property” form. (See Ptf’s Ex 5.) He

testified that the assessed value increased by more than three percent per year between 2002 and

2010, in violation of the annual three percent cap on maximum assessed value increases.

In support of Plaintiff’s requested 2010-11 real market value of $162,320, Glenn

provided numerous articles concerning market trends near the January 1, 2010, assessment date

and over the past decade. (See Ptf’s Ex 8-14.) Glenn testified that a graph from “Moodys/REAL

DECISION TC-MD 110508N 3 Commercial Property Price Index * * * * * All Properties - National Index,” illustrating that

2010 prices fell to 2002 levels, and an article from Forbes, also including the “Moodys/Real

Commercial Property Price Index,” are particularly supportive of Plaintiff’s requested real

market value. (Ptf’s Ex 13, 14.) Glenn and Jon both testified that the evidence that 2010 prices

have fallen to 2002 levels supports Plaintiff’s requested real market value, $162,320, which is

the 2004-05 real market value set by BOPTA and is based on the 2002 purchase price of the

subject property. Glenn did not present any comparable sales, but, instead, focused on the

evidence presented by Defendant at the BOPTA hearing and at trial.

Russell testified that the subject property is a medical office, and there are not many sales

of medical offices to consider. He testified that the August 2008 sale of an office property

located “directly behind” the subject property4 for $218,624 is the best evidence of value. (Def’s

Ex A-5, A-22, 2C.) Russell testified that he confirmed the sale price with the buyer and the

seller, both of whom stated that the “terms did not have any bearing on the sale price.” (See

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Koch Inc. v. Malheur County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/koch-inc-v-malheur-county-assessor-ortc-2012.