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Keywords

appealwillcorporationobjectioncredibility

appealwillcorporationsustainedcredibility

Related Cases

Target Corp. v. Greene Cty. Bd. of Revision, 122 Ohio St.3d 142, 909 N.E.2d 605, 2009 -Ohio- 2492

Facts

The case involves a property tax dispute concerning an 11.82-acre parcel improved with a Target discount store. The Greene County Auditor initially valued the property at $8,188,290, while Target's appraisal determined its value to be $4,500,000 based on a sales-comparison approach. The BTA adopted Target's valuation after finding no evidence to support the county's higher valuation.

The tax year at issue is 2005, and the property at issue consists of an 11.82–acre parcel improved in 1998 with a Target discount store that encompasses 122,522 square feet.

Issue

Did the Board of Tax Appeals err in adopting the reduced valuation of the property based on the appraisal presented by Target Corporation?

Rule

The BTA's decision must be supported by reliable and probative evidence, and the court will not reverse the BTA's determination on credibility of witnesses unless there is an abuse of discretion.

Analysis

The court found that the BTA's reliance on Target's appraisal was justified, as the appraisal used comparable sales data that reflected the market conditions for big-box retail properties. The county's objections regarding the comparability of the properties used in the appraisal were dismissed due to a lack of evidence supporting their claims.

The BTA found that Target's appraisal sustained its burden to show a value different from the one adopted by the BOR. Noting that the county had presented no evidence in rebuttal, the BTA adopted $4,500,000 as the value of the property.

Conclusion

The Supreme Court affirmed the BTA's decision to adopt the value of $4,500,000 for the property, concluding that the BTA's determination was reasonable and lawful.

For all the foregoing reasons, the BTA reasonably and lawfully adopted the conclusion of value propounded by Target's appraiser. We therefore affirm.

Who won?

Target Corporation prevailed in the case because the BTA's decision was supported by reliable evidence and the county failed to provide any competing market information.

The BTA found that Target's appraisal sustained its burden to show a value different from the one adopted by the BOR.

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Prudential Ins. Co. of America v. Commissioner of Revenue, 429 Mass. 560, 709 N.E.2d 1096

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Emery Industries, Inc. v. Limbach, 43 Ohio St.3d 134, 539 N.E.2d 608

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