Ricard v. Klamath County Assessor

Oregon Tax Court·Decided December 16, 2025·No. TC-MD 250142N·Unpublished

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

DONALD-WAYNE RICARD, Beneficiary, ) ) Plaintiff, ) TC-MD 250142N ) v. ) ) KLAMATH COUNTY ASSESSOR, ) ) Defendant. ) DECISION

Plaintiff appealed the real market value (RMV) and maximum assessed value (MAV) of

property identified as Account 396388 (subject property) for the 2023-24 and 2024-25 tax years.

(Compl at 1.) The procedural history of this case is unusual due to the number of motions filed

by Plaintiff, resulting in the following court orders incorporated into this Decision by reference:

Order Denying Default, Granting Site Inspection, entered May 19, 2025; Order Denying Motion

to Quash and Motion for Reconsideration, entered July 9, 2025; Order Denying Plaintiff’s

Motion to Disqualify Presiding Magistrate Allison R. Boomer, entered September 4, 2025; and

Order Setting Schedule, entered September 19, 2025. The last order set forth the parties’

positions as of the case management conference held September 17, 2025, and set a schedule for

the parties to submit evidence to the court. This matter is now ready for decision.

I. STATEMENT OF FACTS

Plaintiff objects to the “unreasonable increase” in the subject property’s value after the

2022-23 tax year. (See Compl at 1.) The subject property’s assessment history is as follows:

2022-23 tax year 2023-24 tax year 2024-25 tax year Land RMV $13,880 $26,660 $28,330 Improvements RMV $0 $132,470 $123,920 Total RMV $13,880 $159,130 $152,250 MAV $6,070 $70,300 $72,400

DECISION TC-MD 250142N 1 (Ptf’s Resp at Exs 2-4, Apr 23, 2025.) On Defendant’s recommendation, the Property Value

Appeals Board reduced the subject property’s 2024-25 improvements value to $59,970 for a total

RMV of $88,300. (Id. at Exs 7-8.) It sustained the 2024-25 MAV. (Id.)

For the years at issue, Defendant originally valued the subject property improvement as a

dwelling. (Or Set Sched at 1.) Plaintiff maintains that it was, instead, a shed that had existed

since his purchase of the subject property in 2016. (See id.) He claims that the shed had no

value. (Id.) Plaintiff alleged that he removed the shed in “late 2023.” (Id.) Plaintiff requests a

total RMV of $10,000 for the subject property. (Compl at 1.)

The court ordered a site inspection at Defendant’s request, but Plaintiff did not comply,

and Defendant abandoned its request. (See Or Deny Default, Gtg Site Inspect; Or Set Sched.)

Nevertheless, Defendant now accepts Plaintiff’s claim that the subject property improvement

was a shed rather than a dwelling. (See Def’s Proposed Changes for 2023, 2024 & 2025, Sep 29,

2025.) Defendant proposed the following values for the 2023-24 and 2024-25 years:

2023-24 tax year 2024-25 tax year Land RMV $16,660 $18,330 Onsite developments $0 $0 Improvements RMV $12,760 $14,674 Total RMV $29,420 $33,004 MAV $11,990 $12,349

(Id. at 2.) Defendant proposed revised values for the 2025-26 tax year, but they are contingent

upon Plaintiff filing an “Application for Reduction of Maximum Assessed Value of Demolished

or Removed Buildings.” (Id. at 1.) The 2025-26 tax year is not pending before the court.

Plaintiff responded that, “for all years in question it would be great if there was no greater

increase then 3% per year due to the fact there were no changes from the year 2016-2023 when I

tore the shed down.” (Ptf’s Resp at 1, Oct 14, 2025.) For evidence in support of his position,

Plaintiff included the subject property’s 2023-24 property tax statement. (Id. at 2.) Regarding

DECISION TC-MD 250142N 2 that property tax statement, Plaintiff explained “you should need no more evidence than that to

make an unbiased ruling.” (Id. at 1.)

II. ANALYSIS

The issue before the court is the RMV and MAV of the subject property for the 2023-24

and 2024-25 tax years. RMV is defined as “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).1 The assessment date for the 2023-24 tax year was January 1, 2023, and the

assessment date for the 2024-25 tax year was January 1, 2024. See ORS 308.007; 308.210. Real

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

by the Department of Revenue[.]” ORS 308.205(2). The department requires consideration of

three approaches to value: the cost approach; the sales comparison approach; and the income

approach. Oregon Administrative Rule (OAR) 150-308-0240(2)(a). MAV is determined in

accordance with ORS 308.146. It increases by no more than three percent per year unless there

is an exception, such as the addition of new property or new improvements to property. Id.

Plaintiff bears the burden of proof by a preponderance of the evidence, which means “the

greater weight of evidence, the more convincing evidence.” ORS 305.427; 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). “Competent evidence includes appraisal reports and sales adjusted

for time, location, size, quality, and other distinguishing differences, and testimony from licensed

1 The court’s references to the Oregon Revised Statutes (ORS) are to 2021. The 2023 version of the ORS is applicable for the 2024-25 tax year, but the relevant provisions cited here were unchanged from the 2021 version.

DECISION TC-MD 250142N 3 professionals such as appraisers, real estate agents, and licensed brokers.” Danielson v.

Multnomah County Assessor, TC-MD 110300D, 2012 WL 879285 at *4 (Or Tax M Div, Mar 13,

2012). The court has jurisdiction to determine the “correct valuation on the basis of the evidence

before the court, without regard to the values pleaded by the parties.” ORS 305.412.

Plaintiff has presented no competent evidence to support an RMV of $10,000 for either

tax year at issue. Plaintiff stated that he removed the shed in late 2023 but presented no evidence

to support that allegation beyond his statement.2 Even if the court accepted Plaintiff’s statement

that he removed the shed, it existed as of the January 1, 2023, assessment date for the 2023-24

tax year. Ordinarily, the court would deny Plaintiff’s appeal based on his failure to meet the

burden of proof. Here, however, Defendant has proposed value reductions for the two tax years

at issue that are favorable to Plaintiff. The court accepts Defendant’s proposed values.

III. CONCLUSION

Upon careful consideration, the court finds that Plaintiff failed to meet his burden of

proof. However, the court accepts Defendant’s proposed value reductions for the 2023-24 and

2024-25 tax year. Now, therefore,

IT IS THE DECISION OF THIS COURT that, for the 2023-24 tax year, the RMV of

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Ricard v. Klamath County Assessor, (Or. Super. Ct. 2025).

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Related

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)