Lawrence v. Washington County Assessor

CourtOregon Tax Court
DecidedSeptember 4, 2013
DocketTC-MD 130103C
StatusUnpublished

This text of Lawrence v. Washington County Assessor (Lawrence v. Washington 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
Lawrence v. Washington County Assessor, (Or. Super. Ct. 2013).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

JUSTIN LAWRENCE, ) ) Plaintiff, ) TC-MD 130103C ) v. ) ) WASHINGTON COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff has appealed the real market value (RMV) of a duplex identified in the

assessor’s records as Account R473455 for the tax years 2011-12 and 2012-13. Trial in the

matter was held by telephone July 31, 2013. Plaintiff, a mortgage broker and real estate owner,

appeared and testified on his own behalf. Defendant was represented by Garrison Winkle-Bryan,

a registered property appraiser with Washington County. Plaintiff’s exhibits 1 through 15, and

Defendant’s exhibit A, were admitted at trial.

I. STATEMENT OF FACTS

A. The subject property

The subject property is a 3,136 square foot duplex built in 1975 and purchased by

Plaintiff on January 21, 2011, for $149,000. (Def’s Ex A at 5; Ptf’s Ex 2.) The property had

been listed for sale on several occasions beginning in April 2008 for $379,000. (Ptf’s Ex 3.)

The list price was reduced to $359,900 in May 2008 (approximately a month after the $379,900

listing), then reduced to $299,900 on February 2, 2009. (Trl Test; Ptf’s Ex 3.) The February

2009 listing at $299,900 was an attempted short sale. (Def’s Ex A at 5; Ptf’s Ex 3.)1 After a

1 Although neither party testified to the property’s listing history before 2009, Plaintiff’s exhibits show the home was listed on April 29, 2008, for $379,000, and then reduced approximately one month later to $359,000. It continued to be listed for $359,000 for at least six months (until October 25, 2008), and was later reduced to the $299,000 figure on February 2, 2009. (Ptf’s Ex 3.)

DECISION TC-MD 130103C 1 number of price reductions, the bank foreclosed on the property in October 2009, and listed the

duplex for $259,900. (Def’s Ex A at 5.) Following a failed sale, the property was again listed in

April 2010, for $218,900. (Id.) The asking price had been reduced to $175,900 as of September

1, 2010, and subsequently reduced to $156,900 as of December 27, 2010, before being purchased

by Plaintiff for $149,000. (Ptf’s Ex 2.) According to the uncontroverted testimony, the property

was twice offered for sale at auction; neither auction generated a sale.

The property is located on SW Walnut Street in West Tigard, which the parties agree is a

busy thoroughfare. The street is paved, 50 feet wide, and has a middle turn lane. (Trl Test; See

also Def’s Ex A at 5; Ptf’s Ex 10.) Both units in the duplex are approximately 1,500 square feet

in size, and the structure is located on slightly less than one acre of property (0.93 acres). (Def’s

Ex A at 5.) Each two-story unit has three bedrooms and two bathrooms, and there is an attached

two-car garage. (Def’s Ex A at 5; Ptf’s Ex 1.) The parties agreed at trial that the duplex has

three parking spaces. There are two garage bays, one for each tenant, and one additional parking

spot next to the garage that is presumably shared by the two duplex tenants. (Def’s Ex A at 5.)

The parties also agree that there is no on-street parking allowed in front of the subject property,

and, according to Plaintiff, the nearest additional parking is two blocks away.

The duplex is located on a steeply sloped lot, and Plaintiff testified that there is no access

to the back yard from the front. Photographs submitted by Defendant support that testimony.

(Def’s Ex A at 10.) Due to the steep topography, the duplex has one level of above-grade living

space, and additional living space below grade in what is sometimes referred to as a finished

daylight basement. According to the uncontroverted testimony, only one of the three bedrooms

in each unit is on the upper above grade level.

///

DECISION TC-MD 130103C 2 Defendant’s appraisal indicates that “[t]he property lies within a drainage hazard buffer

and is considered to be uninhabitable wetlands with no functional utility,” and that the “site

improvements [which include the structure, driveway, and single additional parking space] are

located on the far northwest corner of the property which limits the available parking.” (Def’s

Ex A at 5.) The parties agree that the duplex is of average quality construction. (See id.)

Plaintiff testified on cross examination that the property needed work when he bought it and that

it took three to four months for Plaintiff to rent the property after his purchase. Plaintiff further

testified that he rents each unit for $1,200 per month, but that the price includes utilities, which

average approximately $230 per month.

The subject property has an RMV on the assessment and tax rolls of $293,950 for the

2011-12 tax year and $247,753 for the 2012-13 tax year. (Def’s Ex A at 2; Ptf’s Compl at 2.)2

The 2012-13 roll value reflects a $35,497 value reduction by the Board from the assessor’s

original $283,250 RMV. (See Ptf’s Compl at 2.) The maximum assessed value (MAV) is

$260,820 for the 2011-12 tax year and $268,640 for the 2012-13 tax year. (Def’s Ex A at 2.)

Thus, in accordance with ORS 308.146(2), the assessed value (AV) is $260,820 for the 2011-12

tax year and the $247,753 for the 2012-13 tax year. (Id.; Ptf’s Compl at 2.)

B. The parties’ valuation approaches

1. Plaintiff’s evidence

Plaintiff’s case is based largely on the $149,000 purchase price, the property’s listing

history, and the physical and functional problems affecting the property (only one above-grade

bedroom, limited parking, busy street, steep sloping topography, and inutility of yard the due to

2 Defendant lists the tax year 2012-13 RMV at $283,250 in its valuation report, but the Board order attached to Plaintiff's Complaint for that year indicates that the Board reduced the value from $283,250 to $247,753. (Def’s Ex A at 2; Ptf’s Compl at 2.)

DECISION TC-MD 130103C 3 access problems and wetlands). Plaintiff applies Defendant’s 22 percent market adjustment for

properties that are bank owned or short sales, which increases his January 2011 purchase price of

$149,000 to $182,000. (Trl Test; Def’s Ex A at 12.)3

Plaintiff did present information on four comparable sales, all of which were either bank

owned or short sales. (Ptf’s Ex 1.) Plaintiff testified that comparable sales were submitted as

evidence for the RMV of the subject property as of January 1, 2011. Those sales occurred in

September 2010, February 2011, March 2011, and January 2013. (Id.) Plaintiff indicated

adjustments on his sales grid for all four of his comparable sales, but only applied the

adjustments to his comparable sale number 2. (Ptf’s Trl Test.) The unadjusted sale prices for

comparables 1, 3, and 4 were $144,800, $160,000, and $155,000, respectively. (Id.) Plaintiff’s

comparable 2 sold in January 2013 for $203,000. Plaintiff’s adjusted sale price for that sale,

which was a short sale, is $172,200. (Id.)

2. Defendant’s evidence

Defendant’s appraiser Winkle-Bryan submitted a valuation report which estimates the

value of the subject property on the two applicable assessment dates (January 1, 2011, and

January 1, 2012). (Def’s Ex A.) Winkle-Bryan used all three recognized approaches to value:

the sales comparison approach, the cost approach, and the income approach. (Id. at 3, 12-31.)

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Lawrence v. Washington County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawrence-v-washington-county-assessor-ortc-2013.