Nichols v. Curry County Assessor

CourtOregon Tax Court
DecidedNovember 22, 2022
DocketTC-MD 220152R
StatusUnpublished

This text of Nichols v. Curry County Assessor (Nichols v. Curry 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
Nichols v. Curry County Assessor, (Or. Super. Ct. 2022).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

STEVEN NICHOLS, ) ) Plaintiff, ) TC-MD 220152R ) v. ) ) CURRY COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appealed a Board of Property Tax Appeals (BOPTA) Real Property Order, dated

March 3, 2022, regarding Account R11181 (subject property), for the 2021-22 tax year. A trial

was held remotely via WebEx on November 1, 2022. Plaintiff, Steven Nichols, appeared and

testified on his own behalf. Curry County Appraiser, Lacey Young, appeared on behalf of

Defendant. Curry County Assessor, Jim Kolen, testified as a witness on behalf of Defendant.

Plaintiff’s exhibits 1 to 14 were admitted without objection. The court sustained Plaintiff’s

objection to the admission of Defendant’s exhibits A to E, due to improper service of process.

I. STATEMENT OF FACTS

The subject property is a 1.1-acre lot, located on Highway 101 in Sixes, Oregon that has

formerly been used both for commercial and residential purposes. (Ptf’s Ex 1 at 1; Ptf’s Ex 14.)

At trial, Plaintiff testified that he believes he purchased the subject property in 2003 for $28,000,

and that it is zoned “rural-commercial.” On March 3, 2022, BOPTA mailed Plaintiff a Real

Property Order sustaining Defendant’s real market value (RMV) and assessed values for the

2021-22 tax year at $499,990 and $236,920, respectively. (Compl at 2.)

At trial, Plaintiff testified that years before he purchased the subject property, it was the

site of an operational gas station—the Sixes gas station. Plaintiff further testified that, at some

DECISION TC-MD 220152R 1 point before purchasing the property, one of the gas station’s underground storage tanks leaked,

resulting in the contamination of the subject property’s soil between 4.5 and 5.5 feet beneath the

surface. As evidence of the contamination, Plaintiff submitted a report prepared by the Oregon

Department of Environmental Quality (ODEQ) in April of 2002, which detected 2,220 parts per

million (PPM) of gas and 302 PPM of diesel in soil samples taken from depths between 4.5 and

5.5 feet beneath the surface of the subject property. (Ptf’s Ex 1.) In his case-in-chief, Plaintiff

argued that, as a result of the contamination, the RMV of the subject property is $499,990,

Defendant’s tax roll value, lessened by the cost to conduct an investigation into the scope of the

contamination and the costs to cure the contamination. Plaintiff estimates that these costs would

result in an RMV of approximately $405,857 (rounded).

In his estimation, Plaintiff first allots $55,032 toward the cost to conduct an investigation

into the scope of the contamination, because to Plaintiff’s own admission, it is uncertain if the

2002 ODEQ report still accurately reflects the present condition of the property. In support of

this expense amount, Plaintiff submitted a third-party cost estimate to conduct the investigation,

dated October 19, 2022, provided by Rick Young Seidemann of RYS Environmental LLC. (See

Ptf’s Ex 11.) Second, Plaintiff testified that because the contamination is at a depth of 4.5 to 5.5

feet beneath the surface, he also factored in an expense of $34,811 (rounded) to excavate the

contaminated soil. In support of this figure, Plaintiff submitted as evidence, documentation of a

third-party estimate that he received via email from Rick Coleman of Koos Environmental on

March 12, 2018, to conduct the excavation. (See Ptf’s Ex 5 at 1.) In addition, Plaintiff estimated

that replacing the contaminated soils would cost approximately $3,000. (Ptf’s Ex 6.) However,

Plaintiff submitted no evidence in support of how he reached this figure—a figure that he

DECISION TC-MD 220152R 2 testified to calculating himself.1 Finally, in his testimony, Plaintiff appeared to express an

intention to include what he referred to as ODEQ “oversight costs” in his estimate of the cost to

cure, referencing numerous ODEQ invoices, the most recent dated April 23, 2022, with a balance

due of $1,290 (rounded). (See Ptf’s Ex 9; see also Ptf’s Ex 10.)

Jim Kolen, Curry County Assessor, testified that the RMV of $499,990 on Defendant’s

tax roll, affirmed by the Board in its Real Property Order, is supported by comparable sales that

take the contamination issue associated with Plaintiff’s property into account.

II. ANALYSIS

The issue is the subject property’s RMV for the 2021-22 tax year. RMV 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).2 The assessment date for the 2021-22 tax year is

January 1, 2021. See ORS 208.007; ORS 308.210. The RMV of property “shall be determined

by methods and procedures in accordance with rules adopted by the Department of Revenue[.]”

ORS 308.205(2). RMV is determined using three methods: (1) the cost approach; (2) the sales

comparison approach; and (3) the income approach. OAR 150-308-0240(2)(a); see also Allen v.

Dept. Of Rev., 17 OTR 248, 252 (2003). Although all three approaches must be considered, all

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

///

1 The court notes that while, at trial, Plaintiff requested that his property’s RMV be reduced both by Rick Coleman’s $34,811 (rounded) estimate and by an additional $3,000 to replace the excavated soil, Plaintiff’s exhibit 5 (Coleman’s estimate), appears to indicate that it includes the cost of replacing the excavated soil. (See Ptf’s Ex 5 at 1 (“If you can deliver and grade 100 yards of crushed rock as backfill, please include in quote as well”).) Despite this discrepancy, the court continues its analysis considering both requests as nonduplicative. 2 The court’s references to the Oregon Revised Statutes (ORS) are to 2019.

DECISION TC-MD 220152R 3 As the party seeking affirmative relief, Plaintiff bears the burden of proof and must

establish his 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 Rev., 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 RMV of their property.” Woods v.

Dept. of Rev., 16 OTR 56, 59 (2002) (citation omitted). “[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).

Plaintiff argues that his property’s RMV was effectively reduced by approximately

$100,000, based on the gas and diesel contamination. As evidence, Plaintiff relies upon: (1) a

third-party quote to investigate the condition of the property; (2) numerous third-party quotes to

cure the property, albeit some, if not all, are based on Plaintiff’s own description of the condition

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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)
Allen v. Department of Revenue
17 Or. Tax 248 (Oregon Tax Court, 2003)
Woods v. Department of Revenue
16 Or. Tax 56 (Oregon Tax Court, 2002)
Covington v. Dept. of Rev.
24 Or. Tax 77 (Oregon Tax Court, 2020)

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Nichols v. Curry County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nichols-v-curry-county-assessor-ortc-2022.