The Owner of a lakeside rental property failed to connect her market evidence to the relevant valuation date. Consequently, the Tax Court affirmed the partial denial of Owner’s assessment appeal for the March 1, 2009 assessment date (and its corresponding January 1, 2008, valuation date – a quirk of Indiana law at the time).  In Gillette v. Brown County Assessor (June 7, 2016), Owner argued that the Indiana Board of Tax Review improperly rejected her entire evidentiary presentation, which included (i) rental insurance policy declarations for 2005 to 2012; (ii) a 1998 appraisal; (iii) a 2006 appraisal; and (iv) testimony regarding the property’s potential rental income and sales price.  But Owner failed to relate her evidence to the applicable valuation date.  The Indiana Board, therefore, did not err in rejecting that evidence, the Court concluded.

The Indiana Board had lowered the property’s assessment to its prior year’s value because the Assessor failed to meet her burden of proof justifying the year-over-year increase.  The Assessor, in fact, had conceded that the reduction was appropriate.  Owner sought, but could not support, a further reduction.  Before the Tax Court, she complained that the Indiana Board was required to determine the property’s value using a gross rent multiplier.  The Court, however, would not reverse the Indiana Board’s ruling on that basis.  Owner did not show that the Indiana Board’s concluded value was unreasonable.