MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604).

CourtSupreme Court of Alabama
DecidedJanuary 17, 2025
DocketSC-2024-0013
StatusPublished

This text of MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604). (MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604)., (Ala. 2025).

Opinion

Rel: January 17, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2024-2025

_________________________

SC-2024-0013 _________________________

MBN 500-1200 Buildings, LLC

v.

Alabama Department of Revenue

Appeal from Shelby Circuit Court (CV-18-900604)

SC-2024-0014 _________________________ SC-2024-0013 and SC-2024-0014

MBN Building 300, LLC

Appeal from Shelby Circuit Court (CV-18-900605)

COOK, Justice.

SC-2024-0013 -- AFFIRMED. NO OPINION.

SC-2024-0014 -- AFFIRMED. NO OPINION.

See Rule 53(a)(1) and (a)(2)(F), Ala. R. App. P.

Shaw, Wise, Sellers, Mendheim, Stewart, and Mitchell, JJ., concur.

Cook, J., concurs specially, with opinion.

Parker, C.J., dissents.

2 SC-2024-0013 and SC-2024-0014

COOK, Justice (concurring specially).

I concur fully with this Court's decision to affirm the judgments. I

write specially, however, because this case illustrates how a rule of

evidence can help generate a result that some might consider mistaken

and to explain why the applicable rule of evidence in these cases might

need to be reconsidered.

Background

To summarize a complicated record, MBN Building 300, LLC, and

MBN 500-1200 Buildings, LLC (collectively referred to as "MBN"), each

own commercial office buildings in Hoover. After the Shelby County Tax

Commissioner's Office assessed the fair market values of those buildings

-- Building 300, Building 500, and Building 1200 -- for the 2018 tax year,

MBN challenged those assessments before the Shelby County Board of

Equalization and Adjustments ("the BOE"). The BOE affirmed the

Commissioner's assessments.

MBN then appealed those assessments1 to the Shelby Circuit

1MBN initially appealed only the BOE's assessed values for the buildings for the 2018 tax year, but the assessed values for the 2019, 2020, 2021, 2022, and 2023 tax years were subsequently added to the appeals below.

3 SC-2024-0013 and SC-2024-0014

Court2 and requested a jury trial to determine the fair market values of

those buildings. After the Alabama Department of Revenue ("ADOR")

filed a notice of appearance and became the named "appellee" in the

appeals below,3 the cases were tried together.

I. The Trial

The jury had a tough assignment. Establishing the fair market

value for a commercial office building is not simple or exact. There are

far fewer comparable sales as would exist for ordinary home sales.

Establishing a value is especially difficult when, as here, one of the

buildings at issue -- Building 300 -- produced no income and had no

tenants during any of the pertinent tax years (and Building 500 had no

tenants for a significant number of those years). For the purposes of this

writing, I note that MBN and ADOR presented the following relevant

evidence and arguments to the jury concerning the valuations for the

2See §§ 40-3-24 and 40-3-25, Ala. Code 1975.

3The BOE initially entered a limited appearance in the appeals for

the purpose of submitting its "Certified Statement of Assessment or Valuation" for the buildings pursuant to § 40-3-25, Ala. Code 1975. ADOR subsequently filed a notice of appearance, see § 40-3-26(b), Ala. Code 1975, and became the named "appellee" in the appeals below.

4 SC-2024-0013 and SC-2024-0014

pertinent tax years.

A. ADOR's Expert-Opinion Testimony

At trial, ADOR explained the methods used by the Shelby County

Tax Commissioner and the BOE to arrive at the assessed values in these

cases and argued that the way they assessed the values for the buildings

was more reliable than the expert testimony of the appraisers offered by

MBN. In support of this position, ADOR had Lisa Cooley, the chief

appraiser of the Shelby County Tax Commissioner's Office, testify as an

expert witness.

Cooley testified that the original assessed values set by the

Commissioner were determined by using the "cost approach." To arrive

at those values, Cooley explained that the tax assessor inventoried all

improvements to the buildings, estimated the current cost to construct

similar buildings, and discounted for depreciation. Cooley also testified

that the cost approach was generally accepted and was a good way to

value the buildings.

Additionally, Cooley testified that, in completing the assessment

process, the BOE engages in "mass appraisal" and "equalization." As part

of the BOE's "mass-appraisal" process, Cooley explained, the BOE

5 SC-2024-0013 and SC-2024-0014

"equalizes" assessed tax values so that similar properties in a similar

area are "treated equally." As part of that process, she stated, the BOE

considers the market in areas with "the same attributes, the same traffic

counts, the same school district, [and] the same city limit." Properties

that are of the same "building types" within each of those areas are

considered together. Cooley testified that only rarely can a building

deviate from its equalized value. 4

Cooley further explained that, as a part of this mass-appraisal

process, the Shelby County Tax Commissioner's Office reviews actual

property sales of only "validated properties" in similar areas and

calculates per-square-foot values, which are then compared to all

appraised tax values in the area. According to Cooley, the Shelby County

Tax Commissioner's Office must forward its validated properties to

ADOR. The assessed values, she explained, are required to be between

98% and 102% of those validated sale prices.

4When asked why a property would be valued differently from the

properties used to equalize it, Cooley explained that there would be a deviation if a specific property has "structural damages," like if "tornadoes come through, and maybe it hit one building and it didn't [hit] other[s]." Even if a deviation from the equalized value is permitted due to structural damage, however, Cooley explained that the deviation is removed once the damage is repaired. 6 SC-2024-0013 and SC-2024-0014

Finally, Cooley claimed that mass appraisal is not subjective and is

designed to eliminate "all guesswork" and "all uncertainty." Cooley

contrasted the BOE's mass-appraisal approach with MBN's approach,

which she described as being "very opinionated."

Notably, Cooley also testified that the Shelby County Tax

Commissioner's Office would consider any income information provided

by the property owner and would appraise the property using an "income

approach," if requested. However, no such documentation was provided

by MBN before it initiated the appeals below regarding Building 300 and

Building 500. One possible reason for MBN's not doing so could have been

because Building 300 had no tenants during any of the pertinent tax

years and because Building 500 had no tenants for a significant portion

of those years. As a result, there was no "income" that could have been

submitted for consideration.

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MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mbn-500-1200-buildings-llc-v-alabama-department-of-revenue-appeal-from-ala-2025.