Shenandoah Associates v. Shenandoah County

62 Va. Cir. 231, 2003 Va. Cir. LEXIS 89
CourtShenandoah County Circuit Court
DecidedJuly 2, 2003
DocketCase Nos. (Law) CL98-132 and CL01-140
StatusPublished

This text of 62 Va. Cir. 231 (Shenandoah Associates v. Shenandoah County) is published on Counsel Stack Legal Research, covering Shenandoah County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shenandoah Associates v. Shenandoah County, 62 Va. Cir. 231, 2003 Va. Cir. LEXIS 89 (Va. Super. Ct. 2003).

Opinion

By Judge Dennis L. Hupp

The petitioner, Shenandoah Associates (hereinafter “owner”), owns improved real estate in the Town of Woodstock known as John S. Perry House. This is a sixty-two-unit, housing facility for the elderly and handicapped. In 1996, the County of Shenandoah assessed the property as follows: land: $151,800.00; building: $2,154,600.00; total: $2,305,400.00. The owner claims that this valuation is erroneous and petitions this court to correct the tax assessments based thereon pursuant to Virginia Code § 5 8.1 - 3984. The owner has filed two petitions, the first bearing docket number CL98-132 pertaining to the tax years 1996, 1997, and 1998, and the second bearing docket number CL01-140 pertaining to tax years 1999 and 2000. These were heard together.

The assessment made by the County enjoys a presumption of correctness, American Viscose Corp. v. City of Roanoke, 205 Va. 192, 135 S.E.2d 795 (1964); Fruit Growers Express Co. v. City of Alexandria, 216 Va. 602, 221 S.E.2d 157 (1976). The presumption can be rebutted upon showing of manifest error or total disregard of controlling evidence. Arlington County Bd. v. Ginsberg, 228 Va. 633, 325 S.E.2d 348 (1985). See also Virginia Code § 58.1-3984.

[232]*232There is some confusion surrounding the appraisal method employed by the County. In answers to interrogatories, the Shenandoah County Commissioner of the Revenue had responded that the cost approach was used in valuing the property; however, Michael Didawick of Blue Ridge Appraisal Company, the firm that conducted the subject re-appraisal of Shenandoah County real estate, testified that a “market study” was performed and served as the basis for the valuation. He stated that this was the normal manner in which his firm conducted a “mass appraisal.” He suggested that it was not possible to do a normal sales comparison for each parcel, as one might do in a “fee appraisal,” because of the enormity of the task at hand. He explained that a market study involved making a general comparison of similar types of property in the various jurisdictions in which his firm conducted appraisals rather than making comparisons to specific properties. He further explained that the resulting value for each property was then broken down in a cost-approach format on the tax assessment cards kept and maintained by the Commissioner’s Office whereby values were assigned to various aspects of the improvements. The reason for this remains unclear to me.

In my view, the owner challenges the County’s appraisal on two grounds primarily. First, the owner contends that the County used the cost-less-depreciation approach in its appraisal and that the Virginia Supreme Court has rejected the use of this approach for tax assessment purposes. Secondly, the owner points out that the County failed to give consideration to the special nature of this property, that it is government-regulated, in any appraisal method it employed in this case.

The owner also argues that the County employed the more common valuation methods only after this litigation ensued and that its analysis under each method is flawed.

In the first regard, I do not believe that the Virginia Supreme Court has enunciated any blanket proscription against the use of the cost approach in appraising real estate for tax purposes. The Court ruled that “the use of depreciated reproduction cost as the sole basis for determining fair market value is erroneous only where the taxing authority fails to consider other factors that plainly show such a method ‘would patently lead to unfair and improper results’.” (Citations omitted.) Tidewater Psychiatric Inst. v. City of Virginia Beach, 256 Va. 136, 142, 501 S.E.2d 761 (1998). See also Board of Supervisors v. HCA Health Services, 260 Va. 317, 330, 535 S.E.2d 163 (2000). Here, notwithstanding the interrogatory response of the Commissioner [?]*?of the Revenue, the cost approach was not used by the County in the original reassessment.

The owner has been persistent in arguing that the capitalization-of-income approach is the only valid method of appraising this type of property and that the County erred when it ignored this appraisal method initially. The Virginia Supreme Court, as far as I can tell, has never ruled that the income approach must be used in appraising income-producing property. Indeed, by way of example, I note that it has insisted that a recent sale of the same property be considered in determining fair market value, and this would entail a market-type analysis. Board of Supervisors v. Donatelli & Klein, 228 Va. 620, 325 S.E.2d 342 (1985); and Arlington County Bd. v. Ginsberg, 228 Va. 633, 325 S.E.2d 348 (1985). The Court has acknowledged that the income approach is the preferable method in appraising such property. Arlington County Bd. v. Ginsberg, supra, at 640; and Nassif v. The Board of Supervisors, 231 Va. 472, 484, 345 S.E.2d 520 (1986). The Court has further ruled that, if the capitalization of income method is used, then actual contract rents must be considered. Fairfax County v. Nassif, 223 Va. 400 (1982); and Tysons International v. Board of Supervisors, 241 Va. 5 (1991).

The owner’s experts both employed the capitalization-of-income approach, and both rejected other appraisal methods. Kevin Nolan, areal estate appraiser from Texas, adopted the appraisal report prepared by an associate in his firm and testified that the cost approach was not appropriate because this was not new construction and that the market approach was not appropriate because there were no local sales of this type of property, that it is government-regulated, for comparison. He opined that the income approach was the only appropriate method of valuation, and, in using it, he determined the value of the property to be $1,874,000.00. Kenneth Peltzer, Ph. D., M.A.I., a long-time Virginia real estate appraiser, also declined to use the cost and market approaches for the same reasons as suggested by Mr. Nolan. Dr. Peltzer appraised the property at $1,730,000.00.

As I understand his testimony, Mr. Nolan, in determining net income for the property, used actual contract rents but then used projected expenses for all years after the first year, 1996. He then conducted a discounted cash flow analysis made necessary by reason of the H.U.D. restrictions on this property. Under this analysis, Mr. Nolan found diminishing annual net income for the period of 1996 through 2002, specifically a fall from $221,206.00 in 1996 to $178,733.00 in 2002. He employed a “going-in” capitalization rate of 10.6% and a “terminal” capitalization rate of 11.6%. As I understand it, the higher [234]*234rate factors in the projected decreased annual income under his discounted cash flow analysis.

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Related

Board of Supervisors v. HCA Health Service of Virginia, Inc.
535 S.E.2d 163 (Supreme Court of Virginia, 2000)
Tidewater Psychiatric Institute, Inc. v. City of Virginia Beach
501 S.E.2d 761 (Supreme Court of Virginia, 1998)
Arlington County Board v. Ginsberg
325 S.E.2d 348 (Supreme Court of Virginia, 1985)
Board of Supervisors v. Donatelli & Klein, Inc.
325 S.E.2d 342 (Supreme Court of Virginia, 1985)
Tysons International Ltd. Partnership v. Board of Supervisors
400 S.E.2d 151 (Supreme Court of Virginia, 1991)
Fruit Growers Express Co. v. City of Alexandria
221 S.E.2d 157 (Supreme Court of Virginia, 1976)
American Viscose Corp. v. City of Roanoke
135 S.E.2d 795 (Supreme Court of Virginia, 1964)
Board of Supervisors of Fairfax County v. Nassif
290 S.E.2d 822 (Supreme Court of Virginia, 1982)
Nassif v. Board of Supervisors
345 S.E.2d 520 (Supreme Court of Virginia, 1986)

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62 Va. Cir. 231, 2003 Va. Cir. LEXIS 89, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shenandoah-associates-v-shenandoah-county-vaccshenandoah-2003.