Simpson v. Benton County Assessor

CourtOregon Tax Court
DecidedMay 21, 2019
DocketTC-MD 180234N
StatusUnpublished

This text of Simpson v. Benton County Assessor (Simpson v. Benton 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
Simpson v. Benton County Assessor, (Or. Super. Ct. 2019).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

KEVIN SIMPSON, TR, ) ) Plaintiff, ) TC-MD 180234N ) v. ) ) BENTON COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION1

Plaintiff appeals the 2017-18 real market value and maximum assessed value of property

identified as Account 83513 (subject property). A trial was held on December 18, 2018, in the

courtroom of the Oregon Tax Court in Salem, Oregon. Plaintiff appeared and testified on his

own behalf. Kacie Ropp (Ropp), Property Appraiser, appeared and testified on behalf of

Defendant.

Plaintiff’s Exhibits 1 and 2 and Defendant’s Exhibits A through H were received without

objection. Plaintiff offered several additional exhibits on rebuttal, including letters from two

contractors, comparable sales, and Defendant’s 2017 Real Market Value Certified Ratio Study

and Report. Defendant objected to those exhibits because they were not timely exchanged.

Generally, exhibits must be exchanged within the time provided by Tax Court Rule-Magistrate

Division (TCR-MD) 12 C(1). However, TCR-MD 12 C(1)(c) states that “[e]xhibits submitted as

rebuttal evidence do not need to be exchanged pursuant to the deadlines stated in TCR-MD 12

C(1)(a).” The court admitted page 36 of Plaintiff’s Exhibit 3, the Certified Ratio Study, which

provided classifications of yard improvements for 2017. The court excluded Plaintiff’s other

1 This Final Decision incorporates without change the court’s Decision, entered May 1, 2019. The court did not receive a statement of costs and disbursements within 14 days after its Decision was entered. See Tax Court Rule–Magistrate Division (TCR–MD) 16 C(1).

FINAL DECISION TC-MD 180234N 1 rebuttal exhibits, finding that they served no rebuttal purpose and should have been exchanged

within the time provided under TCR-MD 12 C(1)(a).

I. STATEMENT OF FACTS

The subject property is a two-story, detached, single-family house built in 1961. (See

Ptf’s Ex 2 at 13, 23; Def’s Ex A at 1.) It is approximately 3,000 square feet2 and situated on a

0.25-acre lot. (See Ptf’s Ex 2 at 13; Def’s Exs A, G.) The subject property is in a neighborhood

of houses built primarily in the 1960s, also situated on 0.25-acre lots. (See Def’s Ex G.)

Plaintiff testified that his family purchased the subject property in 1960 or 1961, when it was one

of the first houses built in its subdivision.

A. Subject Property Quality and Condition as of January 1, 2017

1. Land

Plaintiff testified that the subject property lot is the worst lot in the neighborhood because

it sits in a deep hole, creating numerous problems from water run-off. He provided photos of the

subject property’s steep driveway and, for comparison, photos of the flat neighboring lots. (See

Ptf’s Ex 1 at 18-22.) Plaintiff objected to Defendant’s determination that the subject property’s

land real market value was $184,000, which is approximately the same value assigned to all the

neighboring lots. (See Ptf’s Ex 2 at 35-37.) He also objected to Defendant’s classification of the

subject property land as “average” rather than “fair.” (See id. at 39; Ptf’s Ex 3 at 36.)

///

2 Defendant’s property summary describes the subject property as having 2,993 square feet. (Def’s Ex A at 1.) Plaintiff’s appraisal describes the subject property as having 1,739 square feet of gross living area, 1,327 square feet of finished basement, and 364 square feet of unfinished basement. (Ptf’s Ex 2 at 13.) The “hot pads” rental listing describes the subject property as 3,432 square feet. (Def’s Ex F at 1.)

FINAL DECISION TC-MD 180234N 2 2. Improvements

Plaintiff testified that the subject property’s construction is substandard. He provided

photos to illustrate ongoing problems: a termite infestation; water damage in the bathroom; a

wall replaced three times due to water damage; mold in the basement; carpenter ants in the walls;

dry rot; a crumbling chimney; a door that was boarded up because it was not functional; a roof

that needs to be replaced; a poorly constructed roof that lacks a truss; and rafters pulling away

from the center beam. (See Ptf’s Ex 1 at 1-13, 23-28.) The deck was previously dangerous due

to the potential to collapse, so Plaintiff replaced it in 2016 at a cost of $20,000. (See Ptf’s Ex 1 at

14-16 (deck that was replaced); Def’s Ex D (permits and inspections).) Plaintiff also replaced

the gas furnace in 2016. (See Def’s Ex E (permits and inspections).)

Ropp testified that Plaintiff’s photos are inconsistent with the subject property’s

condition in 2018. She noted that some photos were date stamped from 2018, but others were

from the past. (See generally Ptf’s Ex 1.) Ropp testified, for example, that the first photo was

from July 2014. (Id. at 1.) She and another appraiser from Defendant’s office inspected the

subject property on August 15, 2018, and did not see evidence of dry rot or termites. Ropp

provided photos from the site inspection illustrating some of the items that had been repaired:

concrete aprons had been replaced; the deck was replaced in 2016; the furnace was replaced in

2016; and a bathroom had been remodeled. (See Def’s Ex B at 4-16.) She provided a “hot pads”

ad that expired November 5, 2017, listing the subject property for rent for $1,000.3 (Def’s Ex F.)

It referenced “Extensive Remodeling including Bathrooms and Bedrooms. Grade A Real Oak

Hardwood Floors refinished and additional New Tile flooring, Fresh two tone paint.” (Id. at 1.)

3 The property description in the “hot pads” ad identifies the rent as $2,595 per month. (Def’s Ex F at 2.) No explanation was provided for the discrepancy in rental rates.

FINAL DECISION TC-MD 180234N 3 Plaintiff testified that the photos from 2018 are stamped as such but agreed that the other

photos were from earlier time periods. He testified that the photos were not meant to illustrate

the subject property’s current condition, but rather to represent issues that continue to occur.

Plaintiff noted that Defendant described the subject property’s improvements as 95

percent depreciated in 2016-17 but changed them to 21 percent depreciated in 2017-18.

(Compare Ptf’s Ex 2 at 41 with id. at 38.) He noted that Defendant changed the subject

property’s condition from poor (“p”) to average (“a”) and identified it as “class 4,” whereas he

thinks it is a class 1 or 2. (See id. at 38, 41, 47.) Ropp testified that the appraiser who initially

inspected the subject property’s exterior changed its condition from “poor” to “average,” perhaps

based on the new deck and furnace. She testified that Defendant now considers the condition to

be “fair” because the roof needs repair or replacement. Ropp testified that the subject property’s

interior is in “average” condition. She testified that, like the neighborhood, the subject property

is a class 4 based on the Department of Revenue cost factor book. (See Def’s Exs C, G.)

B. Highest and Best Use

Plaintiff testified that the highest and best use of the subject property is to demolish the

house and correct the slope of the lot. To support that conclusion, he provided a contractor’s bid

and an appraisal report, each concluding that the subject property house should be demolished.

The contractor’s bid, dated March 7, 2018, gives the following “site inspection notes”:

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Simpson v. Benton County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simpson-v-benton-county-assessor-ortc-2019.