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2014 Sumner County Reappraisal

Dear Sumner County Property Owners,

As you may be aware, the County Executive and some commissioners have chosen to reject the standard Sumner County appraisal process and have asked the State Board of Equalization to intervene. In a special-called meeting on September 12, 2014, the State Board of Equalization determined there was no wrongdoing with the assessment process and the office of the Assessor and referred the matter back to the County Board of Equalization to validate the informal appeal process. This notice only affects property owners whose value was appealed during the informal appeal process.

What does this mean for you?

The State Board of Equalization has empowered our office to represent you at the County Board meetings. We will notify you, by mail, if the CBOE rejects your appealed value and provide subsequent appeal rights. We encourage you to attend the CBOE meeting which will begin on October 6, 2014 at 9:00 AM in Room 112, County Administrative Building.

The goal of the Assessor’s Office has always been complete transparency for Sumner County citizens. We will be providing updates to this website and encourage you visit often for the latest information.

Please contact our office if you have additional questions regarding this additional appeal process.

A Narrative of the State Board of Equalization Meeting- 09/12/2014

Below is the narrative and comments presented by my office to the State Board of Equalization. I encourage ever citizen to view the video proceedings by clicking here.

It is important to note that three key results were taken from this meeting: (1) The Division of Property Assessments produced no evidence of wrongdoing by the Assessor's office; (2) this was validated by Comptroller Justin Wilson's comments that he sees no wrongdoing or violation of the laws by Mr. Isbell and (3) the State Board of Equalization unanimously voted NOT to revert the values against the property owners, rather refer the matter back the county board of equalization to affirmed the values as agreed between the property owner and the office of the Assessor of Property.

This narrative is written to accompany the attached PowerPoint presented- SBOE_2014_Power_Point. The highlighted section indicates a transition to the next slide.

Members of the State Board of Equalization,

Thank you for the opportunity to speak on behalf of the property owners of Sumner County and defend the appeal process as part of the final phase of the 2014 Reappraisal process.

Allow me to lay a foundation of a historical perspective during my tenure as Assessor of Property in Sumner County.

The last reappraisal in 2009 was primarily administered by the Division of Property Assessments and the informal appeal support was also under the direction of the Division of Property Assessments. Here is a snapshot of the reappraisal.

Total Assessed Value at State FV Meeting- $3,879,832,655
During the informal and county board of equalization appeal process, approximately 20,000 changes were entered resulting in value changes of $123,000,000, with appeals amounting to $95,000,000 remaining to be resolved with the state board of equalization. (The final appeal was resolved in 2013). This reflected a 5.6% change in aggregate value resulting from the appeals process.

In 2011, the Sumner County Sales Ratio study approved by this body indicated an overvaluation of 4%.

A second sales ratio study, completed in 2013 and also approved by this body, indicated an overvaluation of 5.87%.  Therefore, as we began the reappraisal in 2014, we had to address the overvaluation of the 2009 reappraisal.

A snapshot of 2014 Reappraisal

Total Assessed Value at State FV Meeting- $3,949,195,569
During the informal and CBOE appeal process, approximately 25,000 changes were entered, resulting in value changes of $130,800,000, with appeals amounting to under $25,000,000 remaining to be resolved with the SBOE. This represents a 3.95% change resulting from the appeals process.

2009- $218,000,000 in appeals representing a 5.6% reduction in the valuation.
2014- $155,800,000 in appeals representing a 3.95% reduction in the valuation.

The number of appeals may, on the surface, seem high; however, I contend that it reflects that the citizens of Sumner County are engaged in the process.  That is a good thing.  I have worked hard to create that kind of relationship.   I have encouraged citizen participation - in public appearances at civic groups, town hall meetings, radio, and newspaper interviews. My office recognizes that no one knows their property better than the homeowner; and while we physically review every parcel during the four years prior to the final year of the reappraisal, it would be presumptuous to assume that no changes could have been made after our review. We simply do not view the appeal process as adversarial; but rather as an opportunity to strengthen the accuracy of the reappraisal. On a final note, the assertion by the Comptroller’s office that the 2014 reappraisal was an unusual situation is simply not accurate.

Some have suggested that this reappraisal indicates a decline in growth in Sumner County. While our real property assessments declined by 1.59% in total value, relative to 2009, when analyzed relative to the 2013 Sales Ratio study, which indicated a 5.87% over valuation, the net indicates value growth of 4.28%.

Discuss Timing Graph.

A statistical analysis of the mass appraisal process is the standard by which the accuracy and uniformity of reappraisal is judged. I agree with Mr. Jones’ statement that “although the informal review and appeal process will result in changes to individual assessments, the review will hopefully assure the program as a whole complies with accepted measures of assessment level and uniformity (TCA 67-5-1603).

As a general practice, I am not aware of a post-appeal statistical measure being applied in establishing a standard in the appeal process. By the Comptroller’s office own admission this is uncharted territory for his office and with good reason. My research of standards yielded only the IAAO standard. It states, “This informal consideration may, at the option of the property owner, be a face-to-face meeting, telephone conference, or correspondence by mail, fax or electronic mail. An informal consultation allows both parties to consider their positions before a formal appeal is filed. The informal process is highly recommended because it allows a large number of property owners to obtain information, state their grievances, and resolve their appeals in a simple, low-cost manner.” This standard does not apply a numerical value to the appeals process. Moreover, there is no documented, legal standard requiring the maintenance of documents produced during the informal appeals process.

 In fact, there was no analysis performed on the 2009 appeal process supported by Division staff. With this in mind, I have no retrospective statistics for comparison. Also, during the audit of appeal standards by the Division, I made numerous written requests for the state statistical analysis of the 2014 reappraisal appeals process.  I have received no reply from the Division. What was so secretive about the statistical analysis that I could not receive the information during the roughly 45 day appeal process yet prior to the state signing their portion of the reappraisal I could receive a statistical analysis within 24 hours? Even with the intentional stonewalling by the Division of Property Assessments, in the spirit of cooperation, I continued to provide reams of information and available documentation when requested while patiently awaiting an answer to two very simple requests- (1) a statistical analysis of the reappraisal after the appeals process and (2) written documentation of the standards by which this appeals process is being judged. Allow me to make this very clear… I remain committed to discuss every single appeal with the Division of Property Assessment.

The graph shows the primary statistical output used to determine uniformity and equity in assessment for both the pre-appeals and post-appeals time periods.

It is evident that uniformity in assessments are maintained in accordance with TCA 67-5-1603 and serves as the benchmark described by Mr. Jones.

Typically this analysis would end an inquiry outside of any evidence of wrongdoing. I understand the County Executive and his colleagues, acting independent of a formal vote of the County Commission, met with members of Comptroller’s office to discuss the reappraisal. They were advised to formally request an audit, which triggered this process. From the beginning, I have asked for standards of audit for the taxpayer’s right to appeal. I would also extend that questioning to the adopted standards of recordkeeping for the informal appeal process. There are simply no standards that currently exist.

While the reappraisal process remains a complex issue to explain, the facts speak to the accuracy of Sumner County’s reappraisal. In 2011 Sumner County was overvalued by 4.0%. In 2013 Sumner County was overvalued by 5.87%. The reappraisal showed that Sumner County had not rebounded to the values of 2007 and 2008 and recorded in the 2009 Reappraisal; however, it had increased by a remarkable 4.28% in one year resulting in only a 1.59% decrease in aggregate value, comparing 2014 to 2009.

The number of appeals are irrelevant because they are the norm for Sumner County, as indicated by the previous reappraisal conducted by the Division of Property Assessments.

Now let’s looks at the value changes resulting from the appeals process.

43.78% are value changes $10,000 (appraised value) or below. These are typically attributed to minor changes such as corrections resulting from field checks, errors, etc. (show examples of property record cards)

28.61% are value changes greater than $10,000 (appraised value). These may be more closely associated with appeals using sales comparison approach, fee-based appraisals, comparable market analysis, etc. They can also include adjustments in land pricing.

27.59% were increases in property values. These may have resulted from field checks, appeals, etc.

With all due respect, the Division has not provided sufficient explanation or justification for disrupting the property appraisals of thousands of Sumner County property owners.  I remain even more convinced this action originates from a political effort by members of the Sumner County government in a back handed attempt to raise property taxes on residents.  The original property appraisals conducted by my office, and the subsequent reappraisals based on tax payer appeals, followed the same procedures used for over 10 years under my administration and without prior complaint or state intervention.  That leaves the question: “Why are some members of Sumner County government asking the State to intervene?  Why would they want to disrupt the assessments of the property owners in Sumner County?” I do not know the answer to that, but I do know that inflating the aggregate values of the property in Sumner County will result in more taxes being paid by its residents. There have been no incorrect values alleged, no bad acts alleged and my processes are consistent through both reappraisals.

For the SBOE to grant this request would be an unprecedented intrusion by the State of Tennessee into the Sumner County property assessment process.  Moreover, what opportunity will be granted to the citizens to appeal?  How will the people be able to appeal?  What burden are you placing on them?  What chance will they have of getting a fair hearing? In an effort address the real victims of this process - the taxpayers of Sumner County - I ask this body to direct the Sumner County Executive to offer weekend and night appointments for the taxpayers to appeal their values for the second time. Furthermore, due to the expansive geographical boundaries of Sumner County, I request the CBOE meet in various municipalities in addition to the county administration building to further accommodate the citizens. The Assessor’s office remains committed to serving the citizens by supplying support to the taxpayer and CBOE through this process to ensure a fair hearing and proper disposal of their appeals.

Finally, there has been no incorrect values alleged, no bad acts alleged, and I followed the same process as 2009, so why are the taxpayers being put through another appeal process? Why is there a rush to create new policy and apply it retroactively? One thing I have learned through this process is the importance of protecting the integrity of taxpayer’s appeals from unwarranted political intrusion. I am not waiting for the development of a new standard by the state, my office is implementing new procedures to digitally archive informal appeals documents as part of our CAMA system as well as creating an informal appeals database for our sales comparison software.  I will ensure implementation of these procedures to protect the taxpayers will be top priority for my office. The foundation of the Assessor’s office is transparency and integrity, and those principles I will not compromise. I thank you for the opportunity to present and welcome your inquiry into the process.     

Proceedings from the County Board of Equalization

The CBOE will convene on Monday, October 6, 2014 at 9:00 AM in Room 112 of the County Administration Building in Gallatin, TN  to affirm the appeals of Sumner County property owners resulting from the 2014 Reappraisal. Our office will post the decisions made by the CBOE on this site. ONLY property owners whose values are NOT affirmed by the county board will receive written notice with the opportunity to appeal the decision to the county board. 

DAY 1 of the CBOE

The CBOE convened on 10/6/2014 at 9:00am to affirm the values of the citizen's appeals process and subsequent changes. The results are 9,667 property values affirmed and 1,794 property values rejected. All property values rejected by the CBOE are in the Hendersonville area.

Property owners affected by the decision to reject their values will receive a letter outling their rights to appeal. The Assessor's office will be assisting property owner's in the appeal process and encourage you to call upon receipt of the letter as a time specific deadline with be provided.

The CBOE will reconvene on Tuesday, October 14, 2014 at 8:00am in Room 206 of the County Administration Building.