Sowden v. Lincoln County Assessor

CourtOregon Tax Court
DecidedAugust 15, 2012
DocketTC-MD 120145D
StatusUnpublished

This text of Sowden v. Lincoln County Assessor (Sowden v. Lincoln 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
Sowden v. Lincoln County Assessor, (Or. Super. Ct. 2012).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

DOUG S. SOWDEN, ) ) Plaintiff, ) TC-MD 120145D ) v. ) ) LINCOLN COUNTY ASSESSOR ) and DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendants. ) DECISION

Plaintiff appeals the real market value of property identified as Accounts R526957,

R526962, R526959, R526963, R526958, R526961, R526960, R30249 and R27823 (subject

property) for tax year 2011-12. Plaintiff appeared on his own behalf. Peter Boris (Boris)

appeared on behalf of Defendant Lincoln County Assessor. Defendant Department of Revenue

filed a Motion to Dismiss Department of Revenue, stating that “the county is the party

responsible for the appraisal.” At the case management conference held May 9, 2012, Plaintiff

stated that he did not object to Defendant Department of Revenue‟s Motion. With the agreement

of the parties, no one appeared at trial on behalf of Defendant Department of Revenue.

Plaintiff‟s Exhibit, pages 1 through 116, and Defendant‟s Exhibits A through G were

admitted without objection.

I. STATEMENT OF FACTS

Plaintiff‟s testimony consisted of reciting a summary of the list of documents submitted

to the court. (Ptf‟s Ex at 115.) In response to the court‟s questioning, Plaintiff testified that he

did not prepare the appraisal report submitted Plaintiff‟s Exhibit pages 24 through 77. Plaintiff

concluded that the “S corporation” paid for all the improvements and “has a Zero net profit.”

DECISION TC-MD 120145D 1 (Ptf‟s Ex at 116.) He testified that his property taxes have increased “from $2,000 to $12,000.”

He testified that the “county has valued the property at $1.4 Million to $1.5 Million” and he does

“not agree with the county‟s values.”

Boris testified that he “reviewed the appraisal and found it to be compelling since the

data available for an appraisal of condominium units on the central Oregon Coast is limited by

the number of units available in the foreclosure market. I have accepted the value conclusions of

the appraiser with two major exceptions.” (See Def‟s Ex G at 1.) He testified that Plaintiff‟s

appraiser “discounted the values,” making value “a function of ownership.” (See Def‟s Ex G at

1.) Boris testified that “[t]he concept of discounting for multiple property ownership has been

discredited by the Oregon Supreme Court in both of the decisions cited here. See defendant

exhibits E & F.” (See id.) He testified that Plaintiff‟s appraiser “decided the minimally

completed commercial foundations on the remaining tax lots were without value. To say that

construction that is not complete is without value is contrary to the spirit of the concept of value

as brought forth by the Oregon Department of Revenue. Although incomplete, the value as

determined by the percentage completed of the original design is still an improvement to be

valued and taxed.” (See id.)

Boris concluded his testimony by stating that “[a]s of this date, the listing price of the

seven condominiums continues to exceed the Maximum Assessed Value of the units per the

Lincoln County Assessor‟s Office records. [Plaintiff] is not aggrieved on these properties.” (Id.

at 2) He testified that “[g]iven that value is considered a range and that the purpose of the

appraisal is to justify a liquidation value of loan collateral, I feel the values assigned by the

Lincoln County Assessor‟s Office are justified by information provided.” (Id.)

///

DECISION TC-MD 120145D 2 II. ANALYSIS

The issue before the court is the subject property‟s real market value as of January 1,

2011. In Oregon, all real property “not exempt from ad valorem property taxation or subject to

special assessment shall be valued at 100 percent of its real market value.” ORS 308.232.1 ORS

308.205(1) defines real market value 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.”

Real market value is determined by the particular methods and procedures adopted by the

Department of Revenue. ORS 308.205(2). There are three approaches to valuation (income,

cost, and sales comparison) that must be considered when determining the real market value of a

property. Allen v. Dept. of Rev., 17 OTR 248, 252 (2003); Gangle v. Dept. of Rev., 13 OTR 343,

345 (1995); see also OAR 150-308.205-(A)(2)(a) (stating that all three approaches must be

considered, although all three approaches may not be applicable to the valuation of the subject

property). The valuation approach to be used is a question of fact to be determined on the

record. Pacific Power & Light Co. v. Dept. of Rev., 286 Or 529, 533, 596 P2d 912 (1979).

As the party seeking affirmative relief, Plaintiff bears the burden of proving that the

subject property‟s real market value is incorrect on the tax roll. See ORS 305.427. Plaintiff must

establish his claim “by a preponderance of the evidence, or the more convincing or greater

weight of evidence.” Schaefer v. Dept. of Rev., TC No 4530, WL 914208 at *2 (July 12, 2001)

(citing Feves v. Dept. of Rev., 4 OTR 302 (1971)). Plaintiff must present the greater weight of

evidence to support his requested real market value reduction. This court has stated that “ „it is

not enough for a taxpayer to criticize a county‟s position. Taxpayers must provide competent

1 All references to the Oregon Revised Statutes (ORS) and Oregon Administrative Rules (OAR) are to 2009.

DECISION TC-MD 120145D 3 evidence of the [real market value] of their property.‟ ” Poddar v. Dept. of Rev., 18 OTR 324,

332 (2005) (quoting Woods v. Dept. of Rev., 16 OTR 56, 59 (2002) (citation omitted)).

Competent evidence includes, “appraisal reports and sales adjusted for time, location, size,

quality, and other distinguishing differences, and testimony from licensed professionals such as

appraisers, real estate agents, and licensed brokers.” Danielson v. Multnomah County Assessor,

TC-MD No 110300D, WL 879285 (March 13, 2012). Evidence that is inconclusive or

unpersuasive is insufficient to sustain the burden of proof. Reed v. Dept. of Rev., 310 Or 260,

265, 798 P2d 235 (1990).

In the case before the court, Plaintiff submitted an appraisal report but the appraiser who

prepared the report did not testify. (Ptf‟s Ex at 24-77.) The appraisal report stated a date of

value as of July 19, 2011, a date more than six months after the assessment date. (Id. at 24.)

Plaintiff did not consider any of the three approaches to valuation. Plaintiff submitted two

exhibits labeled “Condominiums” for sales in 2010 and 2011, noting that those were “[s]ales

from Lincoln County Assessors site (none of these are from Yachats).” (Id. at 13, 14, 16–18,

115.) Plaintiff did not adjust any of the properties for date of sale, location, condition, size, or

other amenities to make a valid comparison to the subject property. Plaintiff provided listing

information for the subject property that was after the assessment date and did not explain how

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Related

Reed v. Department of Revenue
798 P.2d 235 (Oregon Supreme Court, 1990)
Pacific Power & Light Co. v. Department of Revenue
596 P.2d 912 (Oregon Supreme Court, 1979)
Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)
Gangle v. Department of Revenue
13 Or. Tax 343 (Oregon Tax Court, 1995)
Poddar v. Department of Revenue
18 Or. Tax 324 (Oregon Tax Court, 2005)
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)

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