Moussa v. Deschutes County Assessor

CourtOregon Tax Court
DecidedDecember 23, 2024
DocketTC-MD 230094G
StatusUnpublished

This text of Moussa v. Deschutes County Assessor (Moussa v. Deschutes 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
Moussa v. Deschutes County Assessor, (Or. Super. Ct. 2024).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

GEORGE MOUSSA and ALMA MOUSSA, ) Trustees of the Moussa Family Trust, ) ) Plaintiffs, ) TC-MD 230094G ) v. ) ) DESCHUTES COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiffs appealed the 2022–23 real market value and maximum assessed value of their

home, identified in Defendant’s records as Account Number 260658. Plaintiffs appeared at trial

pro se. Testifying for Plaintiffs were Donald Montagner, appraiser; Nicole Fitch, real estate

broker; and Plaintiff George Moussa. Defendant was represented by its chief appraiser, Todd

Straughan; testifying for Defendant was Dana Meyer, appraiser. Plaintiffs’ Exhibits A to F and

Defendant’s Exhibits A to G were admitted.

I. FACTUAL OVERVIEW

The subject is a newly built custom home in the “mid-century modern” architectural

style—a single story with a flat roof and a minimalist interior that includes high ceilings and

many windows. It is situated on a sloped one-acre lot at the curve of a high-traffic road in the

Tetherow golf resort, just outside Bend. (Exs 1 at 4; A at 8.) It has a gross living area of 3,684

square feet, a 430-square-foot enclosed porch sometimes described as a “rec room,” and a

1,936-square-foot garage. (Exs 1 at 4; A at 4, 7, 31.) It has significant covered outdoor patio

areas and an upper-level deck with a mountain view. (Ex A at 12.) Plaintiffs bought the lot in

May 2019 for $213,500 and completed the improvements in December 2021 at a cost “near

$1,700,000.” (Exs 1 at 13; 6 at 1–2; A at 4.)

DECISION TC-MD 230094G 1 of 2 The real estate market in Bend was “drastically” changing in 2021 and 2022, with

inventory “at historically low levels” and strong demand after a period of uncertainty associated

with the COVID-19 pandemic. (Exs 1 at 14–15; A at 4–8.) Prices increased rapidly throughout

2021; Plaintiffs’ appraiser estimated a 1.52-to-1.70-percent-per-month time trend, while

Defendant’s appraiser estimated a 2.0-percent monthly trend after presenting evidence

supporting a trend of 1.83 to 2.58 percent. (Exs 1 at 17; A at 5–6.)

On the 2022–23 tax roll, Defendant gave the subject a real market value of $2,728,740,

assigning $633,000 to land and $2,095,740 to improvements. (Compl at 3.) Defendant

determined an exception value of $1,821,680 by trending the 2021–22 improvements value

forward one year and subtracting the result—$282,060—from the 2022–23 improvements value,

then adding $8,000 for land exception value attributed to the installation of landscaping.

(Compare Compl at 3 with Ex A at 41.) By applying a changed property ratio of 55.6 percent to

that exception value, Defendant determined a maximum assessed value of $1,497,610. 1 (Id.)

The board of property tax appeals reduced the subject’s 2022–23 land value to $586,026

while sustaining the improvements value, for a total real market value of $2,681,766. (Compl

at 3.) The board removed the $8,000 land exception value and recalculated the maximum

assessed value to be $1,493,160. (Id.)

On appeal here, Plaintiffs ask the court to reduce the subject’s 2022–23 real market value

to $2,462,000. (Ex 1 at 19.) Plaintiffs would assign $597,000 to land value and the remainder to

improvements. (Id. at 16.) Defendant asks the court to raise the subject’s real market value to

$3,080,000. (Ex A at 41.) Defendant would assign $646,000 to land value and the remainder to

improvements, then determine a new exception value (including $8,000 land exception value)

1 By the court’s calculation, the maximum assessed value should have been $1,497,604.

DECISION TC-MD 230094G 2 of 3 and maximum assessed value in the same way described above. Defendant requests a maximum

assessed value of of $1,688,670. (Id. at 41.)

II. ISSUES

What are the subject property’s 2022–23 real market value and maximum assessed value?

III. ANALYSIS

Because the subject is new construction, its 2022–23 real market value is used to

calculate its maximum assessed value. Maximum assessed value is the upward limit on the

amount of value for which a property can be taxed. Although it generally rises by no more than

three percent each year, an exception applies when “new property or new improvements to

property” are added to an account. ORS 308.146(1),(3)(a). 2 Under that exception, maximum

assessed value is calculated by (1) determining the “exception value” (the real market value 3 of

the new property less the value of any retirements), (2) multiplying that value by the “changed

property ratio” (the ratio of average maximum assessed value over real market value in that

county for that property class), and (3) adding the result to what the account’s maximum

assessed value would have been if no new property had been added to it. ORS 308.153(1),(2)(a);

OAR 150-308-0170. 4

In this case it is necessary to find the exception value of the new improvements.

Plaintiffs do not challenge the method followed by Defendant, which is to find the subject’s total

2022–23 real market value, then subtract the portion of that value attributable to the land and

2 The court’s references to the Oregon Revised Statutes (ORS) are to 2021. 3 Real market value is “the amount in cash that could reasonably be expected to be paid by an informed buyer to an informed seller, each acting without compulsion in an arm’s-length transaction occurring as of the assessment date for the tax year.” ORS 308.205(1). 4 Oregon Administrative Rules (OAR)

DECISION TC-MD 230094G 3 of 4 $282,060 (the trended value of the improvements on the prior year’s roll). (Ex A at 41.) The

result is the subject’s 2022–23 exception value, from which its new maximum assessed value can

then be calculated because the other variables are known: the changed property ratio is 55.6

percent, and the maximum assessed value carried forward from the prior year is $487,750. (Id.)

The burden of proof in this court falls on “the party seeking affirmative relief.” ORS

305.427. In other words, the party who seeks a court order changing the current assessment must

provide enough evidence. Here, both parties want to change the assessment. Plaintiffs must bear

the burden to obtain lower tax roll values, and Defendant must bear the burden to obtain higher

values.

The facts to be proved are the subject’s total real market value and the amount of that

value attributable to the land. 5 Each party’s principal evidence is an appraisal report supported

by appraiser testimony. Plaintiffs offered additional exhibits and testimony about the state of the

market and about defects in the subject’s construction, and Defendant offered rebuttal evidence

regarding the comparables chosen in Plaintiffs’ appraisal.

A. Valuation Evidence

Both parties’ appraisers considered the three approaches to value and determined that the

sales comparison approach was the most useful. They agreed that the income approach was not

relevant because homes in Tetherow “are not typically purchased for rental income.” (Exs A at

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Price v. Department of Revenue
7 Or. Tax 18 (Oregon Tax Court, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
Moussa v. Deschutes County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moussa-v-deschutes-county-assessor-ortc-2024.