98-1337

Property Tax/Locally Assessed

Signed

 

BEFORE THE UTAH STATE TAX COMMISSION

____________________________________

WILLIAM & NORENE PETERSEN, ) ORDER

:

Petitioners, : Appeal No. 98-1337

: Parcel No. 001-014-2418

v. :

: Tax Type: Property Tax/Locally Assessed

BOARD OF EQUALIZATION OF ) Recreational Property

DUCHESNE COUNTY, : Tax Year: 1998

UTAH, )

: Judge: Hendrickson

Respondent. : Johnson

_____________________________________

Presiding:

Pam Hendrickson, Commissioner

R. Bruce Johnson, Commissioner

Appearances:

For Petitioner: William and Norene Petersen

For Respondent: Gregory Garff, County Assessor

Kris Bancroft, Deputy Assessor


STATEMENT OF THE CASE

This matter came before the Commission for an Initial Hearing pursuant to the provisions of Utah Code Ann. §59-1-502.5, on May 3, 1999.

STATEMENT OF FACTS

This appeal involves recreational property, including approximately 8.8 acres of land, a 32 foot, 1980, Shasta travel trailer, and a small mountain cottage. There is no dispute regarding the value of the land or the travel trailer. There is a dispute, however, regarding the value of the cottage. The cottage measures 8 feet by 16 feet with a finished interior and a small upper loft, a one-half bath, and a wood burning stove.

The County acknowledged that there are no good comparable sales in the area for the cottage. Accordingly, the County used the Marshall and Swift Residential Cost Handbook for low cost cottages. Applying this methodology, the County arrived at a value of $7,772 as the base cost of the structure of 224 square feet at approximately $35 per square foot. Adding $750 for a one-half bath, $600 for a wood burning stove and pipe, applying the local multiplier and three years of depreciation resulted in a replacement cost new, less depreciation value of $8,282.

The uncontradicted testimony at the hearing, however, was that the mountain cottage measured 8 by 16 feet, or 128 square feet. Although there was some miscellaneous decking, there was no testimony that the size of the cabin should be increased to reflect the deck. Nor was there testimony to indicate the loft would account for the difference. Multiplying the cabin size by $35 per square foot results in a base value of $4,480. Applying the same methodology used by the county assessor, with the smaller size cottage, the value of the cottage would be computed as follows:

Base cost of structure.....................$4,480

Cost for 1/2 bath............................$ 750

Wood Burning Stove & Pipe.........$ 600

$5,830

Local Multiplier X .97

$5,655

Depreciation factor X .936

RCN Less Depreciation $5,293

APPLICABLE LAW

Petitioners have the burden to establish that the market value of the subject property is other than that as determined by Respondent. Utah Admin. R. R861-1A-7(G). To prevail in a real property tax dispute, the Petitioners must (1) demonstrate that the County's original assessment contained error, and (2) provide the Commission with a sound evidentiary basis for reducing the original valuation to the amount proposed by Petitioner. Nelson v. Bd. Of Equalization of Salt Lake County, 943 P.2d 1354 (Utah 1997).

DECISION AND ORDER

Based on the evidence presented at the hearing, we believe Petitioners have carried their burden of proof with regard to the cottage. No adjustment is warranted to the other property. Accordingly, we find that the value of the subject property, as of January 1, 1998, is as follows:

Land.......................$5,300

Cottage...................$5,293

Travel Trailer.........$1,720

Total.................... $12,313

This decision does not limit a party's right to a Formal Hearing. However, this Decision and Order will become the Final Decision and Order of the Commission unless any party to this case files a written request within thirty (30) days of the date of this decision to proceed to a Formal Hearing. Such a request shall be mailed to the address listed below and must include the Petitioner's name, address, and appeal number:

Utah State Tax Commission

Appeals Division

210 North 1950 West

Salt Lake City, Utah 84134

Failure to request a Formal Hearing will preclude any further appeal rights in this matter.

DATED this 7TH day of June, 1999.

____________________________________ ____________________________________

Pam Hendrickson R. Bruce Johnson

Tax Commissioner Tax Commissioner

BY ORDER OF THE UTAH STATE TAX COMMISSION.

The Commission has reviewed this case and the undersigned concur in this decision.

DATED this 7th day of June, 1999.

Richard B. McKeown

Chairman

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