Mughal v. Multnomah County Assessor

CourtOregon Tax Court
DecidedJuly 26, 2019
DocketTC-MD 180118R
StatusUnpublished

This text of Mughal v. Multnomah County Assessor (Mughal v. Multnomah 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
Mughal v. Multnomah County Assessor, (Or. Super. Ct. 2019).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

USMAN A. MUGHAL ) and ZAHRA S. BALOCH, ) ) Plaintiffs, ) TC-MD 180118R ) v. ) ) MULTNOMAH COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiffs appealed a Real Property Order from the Multnomah County Board of Property

Tax Appeals, dated March 7, 2018, for the 2017-18 tax year, and Defendant’s real property

assessment for the 2016-17 tax year. A trial was held on February 5, 2019, in the courtroom of

the Oregon Tax Court. Usman A. Mughal (Mughal) and Zahra S. Baloch (Baloch) appeared and

testified on their own behalf. Carlos Rasch and Scott Elliott appeared on behalf of Defendant.

John James testified on behalf of Defendant.

Prior to the start of trial Defendant moved to exclude Plaintiffs’ exhibits because they

were served untimely. At the initial case management conference, the court set the trial date and

advised the parties that trial exhibits must filed with the court and served on the opposing party

and be postmarked by January 22, 2019 or hand-delivered by January 28, 2019. Those dates

were also contained the court’s trial notice. The notice further references Tax Court Rule –

Magistrate Division (TCR-MD) 12. Mughal stated that he hand-delivered Exhibits 1 to 25 to the

court on January 28, 2019, and mailed the Exhibits to Defendant on that date. Plaintiffs served

the Exhibits on Defendant after the deadline set by the court. Mughal stated that all Exhibits,

with the exception of his appraisal report, Exhibit 15, had been exchanged with Defendant

months before the exchange deadline. Consequently, Exhibit 15 was not admitted into evidence.

DECISION TC-MD 180118R 1 I. STATEMENT OF FACTS

The subject property consists of a 5-bedroom house with approximately 8,118 square feet

of gross living area on a 4.79-acre lot located in the hills just west of downtown Portland. (Ex B

at 5, 12.) The interior and exteriors incorporate top quality imported materials and include

marble flooring, solid quartz countertops in the kitchen, custom banisters, a home theater/media

room, and an extensive stone driveway with stone pillars and railings. (Ex B at 6.) The house

was approximately 60 percent complete as of January 1, 2016, and fully complete before January

1, 2017. Plaintiffs purchased the lot in 2012 for $317,000. (Ex B at 7.) Plaintiffs’ construction

worksheet shows the cost to build the home was $1,670,823. (Ex 14.)

Mughal testified that the house was built as a “dream house” inspired by Moorish

architecture he observed while traveling in Spain. Mughal testified that the subject property’s

value should be reduced for three primary reasons: 1) the land has been settling near the NE

corner causing retaining walls to sink down by several feet; 2) the roof was installed incorrectly,

is leaking, and has been estimated to cost more than $100,000 repair; and 3) the geothermal

system was installed improperly and is raising the ground by several feet. Mughal testified that

80 percent of the lot is subject to a “significant environmental concern” which severely limits the

buildable area of the lot. Additionally, a neighbor has asserted a claim for adverse possession for

a driveway on the SE corner of the lot. Mughal also testified that the subject property is on a

road with a 40 mile-per-hour speed limit and it has no city views.

Mughal acknowledged that there have been several prior appraisals of the subject

property for loan purposes, where estimates of value exceeded $2 million, but those appraisals

did not consider the above problems associated with the property. Mughal submitted estimates

to repair all the defects in the property in the range of $250,000. (Ex 19 to 23, 25.)

DECISION TC-MD 180118R 2 II. ANALYSIS

The issue for this case is the real market value of the subject property for the 2017-18 and

2016-17 tax years. “Real market value is the standard used throughout the ad valorem statutes

except for special assessments.” Richardson v. Clackamas County Assessor, TC-MD 020869D,

2003 WL 21263620 at *2 (Or Tax M Div Mar 26, 2003) (citations omitted). Real market value

is defined in ORS 308.205(1),1 which states:

“Real market value of all property, real and personal, means 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.”

The assessment dates for the 2017-18 and 2016-17 tax years are January 1, 2017 and

January 1, 2016, respectively. ORS 308.007; ORS 308.210. The real market value of property

“shall be determined by methods and procedures in accordance with rules adopted by the

Department of Revenue[.]” ORS 308.205(2). There are three approaches to value that must be

considered: (1) the cost approach; (2) the sales comparison approach; and (3) the income

approach. OAR 150-308-0240(2)(a). Although all three approaches must be considered, all

three approaches may not be applicable in a given case. Id.

The sales comparison approach “may be used to value improved properties, vacant land,

or land being considered as though vacant.” Chambers Management Corp v. Lane County

Assessor, TC-MD 060354D, 2007 WL 1068455 at *3 (Or Tax M Div Apr 3, 2007) (citations

omitted). “The court looks for arm’s length sale transactions of property similar in size, quality,

age and location” to the subject property. Richardson, 2003 WL 21263620 at *3.

“In utilizing the sales comparison approach, only actual market transactions of property comparable to the subject, or adjusted to be comparable, may be used. All transactions utilized in the sales comparison approach must be verified to

1 The court’s references to the Oregon Revised Statutes are to 2015.

DECISION TC-MD 180118R 3 ensure they reflect arms-length market transactions. When non-typical market conditions of sale are involved in a transaction (duress, death, foreclosures, interrelated corporations or persons, etc.), the transaction will not be used in the sales comparison approach unless market-based adjustments can be made for the non-typical market condition.”

OAR 150-308-0240(2)(c).

Plaintiffs bear the burden of proof and must establish their case by a preponderance of the

evidence. ORS 305.427. A “[p]reponderance of the evidence means the greater weight of

evidence, the more convincing evidence.” Feves v. Dept. of Revenue, 4 OTR 302, 312 (1971).

“[I]t is not enough for a taxpayer to criticize a county’s position. Taxpayers must provide

competent evidence of the [real market value] of their property.” Woods v. Dept. of Rev., 16

OTR 56, 59 (2002). “[I]f the evidence is inconclusive or unpersuasive, the taxpayer will have

failed to meet his burden of proof * * *.” Reed v. Dept. of Rev., 310 Or 260, 265, 798 P2d 235

(1990).

The main impediment to Plaintiffs’ case is the exclusion of their appraisal report (Ex 15)

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Related

Reed v. Department of Revenue
798 P.2d 235 (Oregon Supreme Court, 1990)
Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)
Woods v. Department of Revenue
16 Or. Tax 56 (Oregon Tax Court, 2002)
Wihtol I v. Dept. of Rev.
21 Or. Tax 260 (Oregon Tax Court, 2013)

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