In Turoski v. White County Assessor, Pet. No. 91-010-10-1-5-00006 (March 5, 2013) (March 1, 2010 assessment), the Assessor failed to prove that her valuation for the Owner’s residential lakefront property was correct based on a sales ratio study prepared for mass appraisal purposes. The property’s assessment had increased by more than 11% over its 2009 value, so Indiana law assigned the burden of proof on appeal to the Assessor. (Pages 3-4, ¶¶ 11-13) (citing Ind. Code § 6-1.1-15-17.2). The Assessor argued that that the property’s value was correct because a ratio study for the 2010 assessments showed a median ratio of .96 for the property’s neighborhood and .98 for its township as a whole, and the Department of Local Government Finance (“DLGF,” the agency responsible for promulgating Indiana’s property tax assessment rules) required the common level of assessment to fall between .9 and 1.10. She had applied adjustment factors for properties in the neighborhood to make the neighborhood’s mass appraisal “more fair and equitable.” (Page 7, ¶ 23.) The DLGF had approved the Assessor’s ratio study. Because the median ratio for each area met the DLGF’s standards for an acceptable mass appraisal, the Assessor asserted that her assessment of the property must be correct.
But the Assessor “offered no support for the notion that a ratio study may be used to prove that an individual property’s assessment reflects its market value-in-use.” (Page 7, ¶ 22) (emphasis added). The Indiana Board quoted the International Association of Assessing Official’s Standard on Ratio Studies (incorporated by the DLGF’s rules at 50 IAC 27-1-4) as follows:
Assessors, appeal boards, taxpayers, and taxing authorities can use ratio studies . . . to evaluate the fairness of funding distributions, the merits of class action claims, or the degree of discrimination. . . . . However, ratio study statistics cannot be used to judge the level of appraisal of an individual parcel. Such statistics can be used to adjust assessed values on appealed properties to the common level.
Id. (quoting INTERNATIONAL ASSOCIATION OF ASSESSING OFFICIALS STANDARD ON RATIO STUDIES VERSION 17.03 Part 2.3 (Approved by IAAO Executive Board 07/21/2007) (bold added, italics in original)). The Board concluded that the Assessor erroneously relied on “statistics designed to evaluate her mass appraisal of the subject property‘s neighborhood and [township]” in defending her assessment of the individual property’s value. (Pages 7-8, ¶ 24) (emphasis added). The property’s 2010 assessment was reduced to its 2009 value. (Pages 8, ¶ 26.)