Thibodeau v. Denver Cty. Bd. Comm'rs

2018 COA 124, 428 P.3d 706
CourtColorado Court of Appeals
DecidedAugust 23, 2018
Docket17CA0653
StatusPublished
Cited by332 cases

This text of 2018 COA 124 (Thibodeau v. Denver Cty. Bd. Comm'rs) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thibodeau v. Denver Cty. Bd. Comm'rs, 2018 COA 124, 428 P.3d 706 (Colo. Ct. App. 2018).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY August 23, 2018

2018COA124

No. 17CA0653 Thibodeau v. Denver Cty. Bd. Comm’rs — Taxation — Property Tax — Valuation for Assessment

A division of the court of appeals holds that section 39-1-

104(11)(b)(I), C.R.S. 2017, authorizes an assessor to revalue real

property in an intervening tax year if the assessor discovers that the

original assessment was incorrect at the time it was originally done.

While this interpretation was previously announced in 24, Inc. v.

Board of Equalization, 800 P.2d 1366 (Colo. App. 1990), the relevant

statute has been subsequently amended. This decision makes clear

that the statutory amendment did not alter the assessor’s authority

in this regard. Further, in each of the prior published decisions

related to this language, the prior division ruled that although the

assessor had this authority, the taxpayer in that specific case

nevertheless won because the assessor had failed to establish that the original valuation was incorrect. This is the first published

decision where the assessor’s actions are upheld. COLORADO COURT OF APPEALS 2018COA124

Court of Appeals No. 17CA0653 Board of Assessment Appeals Case No. 68926

Joseph H. Thibodeau,

Petitioner-Appellant,

v.

Denver County Board of Commissioners and Board of Assessment Appeals,

Respondents-Appellees.

ORDER AFFIRMED

Division II Opinion by JUDGE TOW Dailey and Casebolt*, JJ., concur

Announced August 23, 2018

N.H. Wright and Associates, Norman H. Wright, Dillon, Colorado, for Petitioner- Appellant

Kristin M. Bronson, City Attorney, Noah Cecil, Assistant City Attorney, Denver, Colorado, for Respondent-Appellee Denver County Board of Commissioners

Cynthia H. Coffman, Attorney General, John A. Lizza, First Assistant Attorney General, Denver, Colorado, for Respondent-Appellee Board of Assessment Appeals

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2017. ¶1 Petitioner, Joseph H. Thibodeau, appeals an order of the

Board of Assessment Appeals (BAA) denying his abatement petition

for the 2014 tax year. We affirm.

I. Background

¶2 Thibodeau purchased the subject property, a residence located

in the City and County of Denver, in July 2013. Earlier that year,

the property was valued at $803,800 for ad valorem tax purposes.

In May 2014, Thibodeau received notice that the City and County of

Denver Assessor’s Office increased its assessment of the property’s

value to $1,169,700.

¶3 Thibodeau unsuccessfully protested the increase with the

Assessor before petitioning for abatement from the Denver County

Board of Commissioners, sitting as the Denver County Board of

Equalization (BOE). Thibodeau argued that the City erred in

reassessing the subject property in an intervening year because no

unusual condition existed. The BOE rejected his claim and upheld

the 2014 assessment.

¶4 Thibodeau then filed an appeal with the BAA, again

contending that the BAA should reduce the subject property’s 2014

value to the 2013 value of $803,800. At the hearing, the BOE

1 requested that the property’s value be lowered from $1,169,700 to

$1,150,000, based on an appraisal by a licensed residential

appraiser. The BAA concluded that the mischaracterization of the

property’s condition as average, rather than good, led to an

incorrect 2013 assessment of the property’s value. Therefore, the

assessor was permitted to correct the incorrect assessment during

the intervening year. Additionally, the BAA found that there was

sufficient evidence to support the value testified to by the appraiser.

¶5 On appeal, Thibodeau argues that the BAA erred in upholding

the City and County of Denver’s reassessment of his property

because section 39-1-104(11)(b)(I), C.R.S. 2017, only permits

redeterminations in intervening years when unusual conditions

exist. He also contends that the reassessment violated his

constitutional right to equal protection in light of the Supreme

Court’s decision in Allegheny Pittsburgh Coal Co. v. County

Commission, 488 U.S. 336 (1989). We consider, and reject, each

contention in turn.

II. Standard of Review

¶6 A challenge to the BAA’s property tax assessment requires us

to review questions of law and fact. We may only set aside the

2 BAA’s decision if the BAA failed to abide by the statutory scheme for

calculating property taxes, or its decision is unsupported by

competent evidence. Jefferson Cty. Bd. of Cty. Comm’rs v. S.T.

Spano Greenhouses, Inc., 155 P.3d 422, 424 (Colo. App. 2006).

Because statutory interpretation is a question of law, we review the

BAA’s interpretation of the relevant statute de novo. Id.

¶7 However, we defer to the BAA’s findings of fact. “It is the

function of the BAA, not the reviewing court, to weigh the evidence

and resolve any conflicts.” Bd. of Assessment Appeals v. Sampson,

105 P.3d 198, 208 (Colo. 2005). And, Thibodeau bears the burden

of proving by a preponderance of the evidence that the property

assessment is incorrect. Id. at 202.

III. Correction of a Property Assessment in an Intervening Year

¶8 Thibodeau first contends that the BAA erred in concluding

that the assessor was permitted to reassess his property value in an

intervening year without showing that an unusual condition

existed. We conclude that section 39-1-104(11)(b)(I) authorizes

assessors to correct incorrect property assessments in intervening

years.

3 A. The Assessor’s Authority

¶9 Section 39-1-104(10.2)(a) provides that “beginning with the

property tax year which commences January 1, 1989, a

reassessment cycle shall be instituted with each cycle consisting of

two full calendar years.” In other words, property value

assessments are calculated once every two years. But,

reassessments of property values are permitted in intervening years

if “any unusual conditions in or related to any real property which

would result in an increase or decrease in actual value” exist.1

§ 39-1-104(11)(b)(I). Additionally, the statute provides that

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2018 COA 124, 428 P.3d 706, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thibodeau-v-denver-cty-bd-commrs-coloctapp-2018.