Swank v. Deschutes County Assessor

CourtOregon Tax Court
DecidedMay 13, 2013
DocketTC-MD 130144C
StatusUnpublished

This text of Swank v. Deschutes County Assessor (Swank v. Deschutes 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
Swank v. Deschutes County Assessor, (Or. Super. Ct. 2013).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

ALBERT E. SWANK ) and DEBORAH S. SWANK, ) ) Plaintiffs, ) TC-MD 130144C ) v. ) ) DESCHUTES COUNTY ASSESSOR, ) ) ) Defendant. ) DECISION OF DISMISSAL

Plaintiffs have appealed the real market value (RMV) of certain real property consisting

of one single tax lot but two separate assessor tax accounts due to a “code split” stemming from

differing fire protection assessments for the property. The appeal concerns the 2012-13 tax year.

Defendant filed an Answer and the court held a case management conference by telephone

May 6, 2013. Albert Swank (Swank) appeared for Plaintiffs. Sean McKenney (McKenney) and

Theresa Maul appeared for Defendant, although only McKenney is officially authorized to

represent the county.

I. STATEMENT OF FACTS

The salient facts, from the testimony and pleadings, are as follows. Plaintiffs purchased a

1,525 square foot home on 7.16 acres in the La Pine, Oregon. (Ptfs’ Compl at 5.) Their offer

was submitted the first day the property was listed for sale, on or about February 10, 2012.

Swank testified that the property was listed on a Saturday and that the seller accepted their offer

two days later on Monday, and McKenney indicated that the property’s listing history indicates

that the property was listed February 10, 2012, and was “pending” on February 13, 2012. The

important point here is that Plaintiffs “purchased” the property in early February, on the same

DECISION OF DISMISSAL TC-MD 130144C 1 day it came on the market, and their offer was accepted within a few days, with the deed

recorded roughly one month later. The date of the parties’ purchase and sale agreement

(approximately February 13, 2012) was shortly after the January 1, 2012, assessment date. The

deed was subsequently recorded March 26, 2012. Plaintiffs paid $149,900 for the property. (See

Ptfs’ Compl at 3.) According to the parties, the seller of the property was a lending institution (a

bank).

Although the property is identified in the assessor’s records as a single tax lot, there are

separate account numbers because the home and five acres are covered by the La Pine rural fire

district, but the remaining 2.16 acres are not. The fire district imposes a tax levy for the fire

protection services it offers and the tax collector must therefore tax the two portions of property

separately. Accordingly, there are two separate account numbers: 127019 and 245176. (Ptfs’

Compl at 2-3.) The assessor placed a total RMV of $157,050 on first account (127019),

comprising the home and five acres, and a total RMV of $22,930 on the second account

(245176), comprised of the 2.16 acres of undeveloped land which Swank testified was in a

floodplain and basically unbuildable and, in his opinion, worth little or no money. The account

with the home (127019) has an allocated RMV of $62,090 for the five acres of land and on-site

developments which the assessor valued at $9,0001 (water, sewer, electric, site preparation,

driveway, and any landscaping, etc.), and $94,960 for the improvements (the home). (See id. at

2.) The RMV for the total tax lot is $179,980 ($157,050 plus $22,930). The property’s

maximum assessed value (MAV) and assessed value (AV) are $132,530 (for the legal tax lot,

both accounts).

///

1 That means the assessor’s five-acre land value, excluding the on-site developments, is $53,090, or approximately $10,000 per acre.

DECISION OF DISMISSAL TC-MD 130144C 2 In their Complaint, Plaintiffs request an adjustment in the RMV of the property – the

home and 7.16 acres – to the $149,900 purchase price. (Ptfs’ Compl at 1.)

II. ANALYSIS

Oregon’s property tax appeal system contemplates an annual challenge to the value of the

property by first filing a petition with the board of property tax appeals (board) after the tax

statements are mailed each year (in October) and before December 31. See e.g. ORS 309.100 and

ORS 309.026(2).2 A taxpayer who timely petitions the board and disagrees with the outcome

can file an appeal with the Oregon Tax Court, Magistrate Division, pursuant to ORS 305.275

(providing for appeals to the Magistrate Division of the tax court by persons aggrieved by an

order of the board) and ORS 305.560 (Oregon Tax Court appeal procedure generally), doing so

within 30 days of the date the board mails its order as provided in ORS 309.110(1) (providing for

disposition of petitions to the board by order of the board) and ORS 305.280(4) (providing for

the 30 day appeal period to the Oregon Tax Court).

Without other statutory authority, a taxpayer’s failure to properly (and timely each year)

pursue the statutory right of appeal by first going to the board and then the Oregon Tax Court,

would be fatal for that year, leaving the taxpayer without a remedy for the year the process was

not correctly followed. However, the legislature determined that certain extraordinary

circumstances exist that merit the court’s review and allow for changes in value where

warranted. See generally ORS 305.288.

However, the statute referenced above that governs appeals to the Magistrate Division

requires a party challenging any determination of the county assessor to be “aggrieved.”

ORS 305.275(1)(a) provides that a person appealing to the Magistrate Division of the Oregon

2 All references to the Oregon Revised Statutes (ORS) are to 2011.

DECISION OF DISMISSAL TC-MD 130144C 3 Tax Court “must be aggrieved.” This court has previously ruled that “[i]n requiring that

taxpayers be ‘aggrieved’ under ORS 305.275, the legislature intended that the taxpayer have an

immediate claim of wrong.” Kaady v. Dept. of Rev., 15 OTR 124, 125 (2000). For there to be

an immediate claim of wrong, the reduction in value must produce a corresponding reduction in

property taxes. Where a reduction in RMV will not reduce taxes, this court has ruled that the

taxpayers are not aggrieved. Paris v. Dept. of Rev., 19 OTR 519, 521-522 (2008) (noting that

ORS 305.275 requires a taxpayer to be aggrieved for the court to have jurisdiction, and finding

that, under the facts of that case, the taxpayers failed to show that their requested reduction in

RMV would reduce their property tax liability); see also Parks Westsac L.L.C. v. Dept. of Rev.,

15 OTR 50, 52 (1999).

The RMV Plaintiff’s request in this case will not reduce their property taxes. At the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kaady v. Department of Revenue
15 Or. Tax 124 (Oregon Tax Court, 2000)
Parks Westsac L.L.C. v. Department of Revenue
15 Or. Tax 50 (Oregon Tax Court, 1999)
Paris v. Dept. of Rev.
19 Or. Tax 519 (Oregon Tax Court, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Swank v. Deschutes County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/swank-v-deschutes-county-assessor-ortc-2013.