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Tax Appeal Rulings - Comfort Inn and Baymont InnCity of Dubuque City Council Meeting Consent Items # 07. Copyrighted June 17, 2024 ITEM TITLE: Tax Appeal Rulings - Comfort Inn and Baymont Inn SUMMARY: Senior Counsel providing a copy two recent rulings by the Iowa Property Assessment Appeal Board upholding the City of Dubuque Board of Review January 1, 2023 assessed values for the Comfort Inn at 4055 McDonald Drive and the Baymont Inn at 4024 McDonald Drive. SUGGESTED Suggested Disposition: Receive and File DISPOSITION: ATTACHMENTS: Description Memo Type Staff Memo Dubuque THE CITY OF DUB TE Ail•Anenr� Cil� . I � z°°�•7* Mas to iece on the Mi issi i �P pp BARRY A. LINDAH E�� SENIOR COUNSEL 20° 9 zoi�#zoig MEMO To: Mayor Brad M. Cavanagh and Members of the City Council DATE: June 17, 2024 RE: Tax Appeal Rulings Attached are two recent rulings by the Iowa Property Assessment Appeal Board upholding the City of Dubuque Board of Review January 1, 2023 assessed values for two properties. The two properties are the Comfort Inn at 4055 McDonald Drive and the Baymont Inn at 4025 McDonald Drive. The owner filed the protests with the Board of Review requesting a reduction in the assessed values. The Board of Review denied the requests and the owner then appealed to the Property Assessment Appeal Board. Working with City Assessor Troy Patzner, we provided evidence to the Property Assessment Appeal Board that supported the Board's denial of the protests. The Property Assessment Appeal Board agreed. BAI_:JLM Attachments CC" Michael C. Van Milligen, City Manager Crenna Brumwell, City Attorney Troy Patzner, City Assessor OFFICE OF THE CITY ATTORNEY DUBUQUE, IOWA SUITE 330, HARBOR VIEW PLACE, 300 MAIN STREET DUBUQUE, IA 52001-6944 TELEPHONE (563) 583-41131 FAx (563) 583-10401 EMAIL balesq@cityofdubuque.org Electronically Filed 2024-05-20 09:33:21 PAAB 2023-104-00446C PROPERTY ASSESSMENT APPEAL BOARD FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER PAAB Docket No. 2023-104-00446C Parcel No. 1028326004 James Madison Hotels, Inc. (Sonny Patel), Appellant, vs. City of Dubuque Board of Review, Appellee. Introduction The appeal came on for consideration by the Property Assessment Appeal Board (PAAB) on April 5, 2024. Sonny Patel represented James Madison Hotels, Inc. and requested the appeal proceed without a hearing. City of Dubuque Senior Counsel Barry Lindahl represented the Board of Review. James Madison Hotels, Inc. (James Madison) owns a commercial property located at 4055 McDonald Drive, Dubuque, Iowa. Its January 1, 2023, assessment was set at $1,732,600, allocated as $247,100 in land value and $1,485,500 in building value. (Ex. A). James Madison petitioned the Board of Review claiming the property's assessment was not equitable as compared with the assessments of other like property in the taxing district and that there was an error in the assessment. Iowa Code § 441.37(1)(a)(1)(a & d). (Ex. C). The Board of Review denied the petition. (Ex. B). James Madison then appealed to PAAB reasserting its inequity claim. It also checked the box on the appeal form asserting there is an error in the assessment. § 441.37(1)(a)(1)(d). However, it did not clearly articulate an error on its Appeal or any subsequent filing. PAAB therefore will only consider its inequity claim. 1 General Principles of Assessment Law PAAB has jurisdiction of this matter under Iowa Code sections 421.1A and 441.37A. PAAB is an agency and the provisions of the Administrative Procedure Act apply. § 17A.2(1). This appeal is a contested case. § 441.37A(1)(b). PAAB may consider any grounds under Iowa Code section 441.37(1)(a) properly raised by the appellant following the provisions of section 441.37A(1)(b) and Iowa Admin. Code R. 701-115.2(2-4). New or additional evidence may be introduced. Id. PAAB considers the record as a whole and all of the evidence regardless of who introduced it. § 441.37A(3)(a); see also Hy-Vee, Inc. v. Employment Appeal Bd., 710 N.W.2d 1, 3 (Iowa 2005). There is no presumption the assessed value is correct, but the taxpayer has the burden of proof. §§ 441.21(3); 441.37A(3)(a). The burden may be shifted; but even if it is not, the taxpayer may still prevail based on a preponderance of the evidence. Id.; Compiano v. Bd. of Review of Polk Cnty., 771 N.W.2d 392, 396 (Iowa 2009) (citation omitted). Findings of Fact The subject property is a three-story, fifty -two -unit hotel built in 1990 and operating as a Quality Inn. It has 23,436 square feet of gross building area and 15,800 square feet of concrete paving. The site is 0.675 acres. (Ex. A). James Madison Hotels purchased the subject property on October 10, 2020 for $1,750,000. The Board of Review notes the January 1, 2023 assessed value of $1,732,500 is still below the sale price. (BOR Ex. List/Narrative). The primary focus of the appeal is the percentage increase of the subject's assessment. James Madison asserts the subject's assessment increased 43% while the increase of its two comparable properties was closer to 25%. (Appeal). In contrast, the Board of Review noted the valuation changes of area hotels from the prior year ranged from 22.7% to 94.5%. "The range of increases were in part from removing prior Board of Review adjustments, land values were adjusted based on prior years of sales in the specific area, and in some circumstances income information was provided." (BOR Exhibit list narrative). On the Petition to the Board of Review, Patel identified two comparable properties: Main Stay Suites and Country Inn & Suites. (Ex. C). According to Patel, their assessments were $3,033,300 and $3,340,600, respectively. Patel asserts the subject's assessment is inequitable compared to these properties. He provided no additional information about the other hotel properties. The subject's current assessment falls well below these assessments. However, he requests a valuation of the subject at $1,358,331. (Appeal). We note this value is well below the subject's 2020 purchase price, and is not supported by any evidence. The Board of Review submitted a narrative exhibit list which explained the valuation changes for hotels near the subject property. It also submitted eight comparable hotel properties and noted, "the hospitality industry uses per hotel room as a unit of comparison when they are marketed." (Exhibit list and Ex. D). The subject's value per room is $33,319, which the Board of Review contends is "in line when compared to other similar class hotels in the area." The following table summarizes seven properties the Board of Review submitted that it believes demonstrates the subject is equitably assessed. (Ex. D). Address Year Built Gross Building Area (GBA) (SF) Room Count 2023 Assessed Value (AV) AV/GBA AV/Room Subject — 4055 McDonald Dr (Quality Inn) 1990 23,436 52 $1,732,600 $74 $33,319 A — 1315 Associates Dr (Country Inn) 2000 42,304 69 $3,340,600 $79 $48,414 B - 1275 Associates Dr (Main Stay Inn) 2000 45,375 75 $3,033,300 $67 $40,444 C — 3100 Dodge St (Best Western) 1978 117,755 150 $8,164,900 $69 $54,433 D — 4025 McDonald Dr (Baymont Inn) 1986 36,262 80 $3,097,800 $85 $38,723 E — 2080 Holiday Dr (Holiday Inn Express) 2008 47,682 87 $4,802,400 $101 $55,200 F — 3400 Dodge St (Fairfield Inn) 1992 25,235 56 $2,158,000 $86 $38,536 G — 3434 Dodge St (Hampton Inn) 1975 58,999 97 $5,711,900 $97 $58,886 H— 2730 Dodge St (Super 8) 1986 20,852 61 $1,686,400 $81 $27,646 The subject property has the second lowest total assessment and assessed value per room. Comparables A, B, and E sold in 2018, 2017, and 2015 respectively. Comparable C is the only recent sale, having sold in 2022. Nothing is known about the sale transactions. There are no time adjustments or any other adjustments to the sales to account for differences that may exist when compared to the subject. 3 Comparables A and B are those Patel identified on the Board of Review petition. According to the Board of Review's exhibit, they are similar in quality (grade) to the subject but their condition is unknown. Their assessments in total and per room are higher than the subject. Only Comparable H has a lower assessment than the subject. Three of these properties are newer than the subject. The subject has the fewest rooms and the second smallest gross building area. Comparable C is the only property that sold in 2022 for $12,036,000. While it is larger, older, and better quality than the subject, its assessed -value -to -sale -price ratio is 0.68, which suggests it is assessed for less than market value. However, again the record contains no information about the sale. Without information about whether the sale was an arm's-length transaction or contained personal property, we cannot rely on it for an indication of the subject's market value. This property's assessment also increased by 94.5% after its sale. Considering the record as a whole, and the lack of other information, the data the Board of Review presented indicates the subject's assessment is in line with other similar hotel properties, whether based on the total assessment or per room valuation. Analysis & Conclusions of Law In Iowa, property is to be valued at its actual value. Iowa Code § 441.21(1)(a). Actual value is the property's fair and reasonable market value. § 441.21(1)(b). Market value essentially is defined as the value established in an arm's-length sale of the property. Id. Sale prices of the property or comparable property in normal transactions reflecting market value, and the probable availability or unavailability of persons interested in purchasing the property, shall be taken into consideration in arriving at its market value. Id. If sales are not available to determine market value then "other factors," such as income and/or cost, may be considered. § 441.21(2). There is no presumption the assessed value is correct, but the taxpayer has the burden of proof. §§ 441.21(3); 441.37A(3)(a). The burden may be shifted; but even if it is not, the taxpayer may still prevail based on a preponderance of the evidence. Id.; Compiano v. Bd. of Review of Polk Cnty., 771 N.W.2d 392, 396 (Iowa 2009) (citation 12 omitted). When the taxpayer "offers competent evidence that the market value of the property is different than the market value determined by the assessor, the burden of proof thereafter shall be upon the officials or persons seeking to uphold such valuation." Iowa Code § 441.21(3). To be competent evidence, it must "comply with the statutory scheme for property valuation for tax assessment purposes." Soifer v. Floyd Cnty. Bd. of Review, 759 N.W.2d 775, 782 (Iowa 2009) (citations omitted). James Madison Hotels claims the subject property's assessment was not equitable as compared with the assessments of other like property in the taxing district. § 441.37(1)(a)(1)(a). To prove inequity, a taxpayer may show an assessor did not apply an assessing method uniformly to similarly situated or comparable properties. Eagle Food Centers v. Bd. of Review of the City of Davenport, 497 N.W.2d 860, 865 (Iowa 1993). Alternatively, a taxpayer may show the property is assessed higher proportionately than other like properties using criteria set forth in Maxwell v. Shivers, 133 N.W.2d 709, 711 (Iowa 1965). The Maxwell test provides inequity exists when, after considering the actual and assessed values of similar properties, the subject property is assessed at a higher proportion of its actual value. Id. This is commonly done through an assessment/sales ratio analysis comparing prior year sales (2022) and current year assessments (2023) of the subject property and comparable properties. James Madison Hotel's primary contention is that the subject's assessed value increased at a higher rate than properties it identified as comparable. It is insufficient to simply compare the subject property's assessed value to the assessments of other properties or the rate of change of property assessments to demonstrate inequity. Even if it were, the record shows the subject's assessment increase was within the range of increases of other area hotels. Further, as previously noted, variation in sizes — whether gross building area or room counts — explains much of the difference in the per unit assessed values and does not demonstrate inequity. Considering the only evidence in the record, the subject property's assessment falls in the low end of the range of other hotels in the area. 5 In the present case, James Madison Hotels provided no evidence that different methods were applied to similarly situated properties. Nor did it provide any recent sales of comparable properties or demonstrate the subject's actual fair market value, which are necessary to calculate an assessment -to -sales -price ratio as provided in Maxwell. Viewing the record as a whole, we find James Madison Hotels has failed to prove the subject property is inequitably assessed. Order PAAB HEREBY AFFIRMS the City of Dubuque Board of Review's action. This Order shall be considered final agency action for the purposes of Iowa Code Chapter 17A. Any application for reconsideration or rehearing shall be filed with PAAB within 20 days of the date of this Order and comply with the requirements of PAAB administrative rules. Such application will stay the period for filing a judicial review action. Any judicial action challenging this Order shall be filed in the district court where the property is located within 30 days of the date of this Order and comply with the requirements of Iowa Code section 441.37B and Chapter 17A. Elizabeth Goodman, Board Member Dennis Loll, Board Member AA, a-t-k__ Karen Oberman, Board Member Copies to: Sonny Patel by eFile City of Dubuque Board of Review by eFile A Electronically Filed 2024-02-23 11:53:50 PAAB 2023-104-00447C PROPERTY ASSESSMENT APPEAL BOARD FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER PAAB Docket No. 2023-104-00447C AM Hotels Inc. (Sonny Patel), Appellant, vs. Parcel No. 1028326005 City of Dubuque Board of Review, Appellee. Introduction The appeal came on for consideration by the Property Assessment Appeal Board (PAAB) on December 1, 2023. Sonny Patel represented AM Hotels Inc. and requested the appeal proceed without a hearing. City of Dubuque Senior Counsel Barry Lindahl represented the Board of Review. AM Hotels Inc. owns a commercial property located at 4025 McDonald Drive, Dubuque, Iowa. Its January 1, 2023, assessment was set at $3,097,800, allocated as $753,000 in land value and $2,344,800 in building value. (Ex. A). AM Hotels petitioned the Board of Review claiming the property's assessment was not equitable as compared with the assessments of other like property in the taxing district. Iowa Code § 441.37(1)(a)(1)(a). (Ex. C). The Board of Review denied the petition. (Ex. B). AM Hotels Inc. then appealed to PAAB reasserting its inequity claim. It also checked the box on the appeal form asserting there is an error in the assessment. § 441.37(1)(a)(1)(d). However, it did not clearly articulate an error on its Appeal or any subsequent filing. PAAB therefore will only consider its inequity claim. 1 General Principles of Assessment Law PAAB has jurisdiction of this matter under Iowa Code sections 421.1A and 441.37A. PAAB is an agency and the provisions of the Administrative Procedure Act apply. § 17A.2(1). This appeal is a contested case. § 441.37A(1)(b). PAAB may consider any grounds under Iowa Code section 441.37(1)(a) properly raised by the appellant following the provisions of section 441.37A(1)(b) and Iowa Admin. Code R. 701-115.2(2-4). New or additional evidence may be introduced. Id. PAAB considers the record as a whole and all of the evidence regardless of who introduced it. § 441.37A(3)(a); see also Hy-Vee, Inc. v. Employment Appeal Bd., 710 N.W.2d 1, 3 (Iowa 2005). There is no presumption the assessed value is correct, but the taxpayer has the burden of proof. §§ 441.21(3); 441.37A(3)(a). The burden may be shifted; but even if it is not, the taxpayer may still prevail based on a preponderance of the evidence. Id.; Compiano v. Bd. of Review of Polk Cnty., 771 N.W.2d 392, 396 (Iowa 2009) (citation omitted). Findings of Fact The subject property is a two-story, eighty -unit hotel built in 1986 and operating as a Baymont Inn and Suites. It has 36,262 square feet of gross building area, comprised of two buildings, an enclosed pool, and 36,200 square feet of concrete paving. The improvements are listed in normal condition with a 4-00 grade (average quality). The improvements have 45% physical depreciation applied to the assessed value. The site is 2.20 acres. (Ex. A). Notes on the property record card indicate multiple permits for interior and exterior remodels between 2012 and 2022 and a new roof in 2023. (Ex. A, p.14). Nonetheless, Patel writes on his appeal form "this is not a new building nor has it been remodeled or updated in the past 10 years." (Appeal). The primary focus of the appeal is the percentage increase of the subject's assessment — AM Hotels asserts the subject increased 45% while comparable property assessment increases were closer to 25%. On the Petition to the Board of Review, Patel identified two comparable properties: Main Stay Suites and Country Inn & Suites. (Ex. C). According to Patel, their assessments were $3,033,300 and $3,340,600, respectively. He states these properties are newer than the subject, in better condition, and have had recent remodels, yet their assessments only increased by 25% and 27% in 2023. Patel asserts the subject's assessment is not correct relative to these properties. Patel provided no additional information about the other hotel properties. respectively. The subject's current assessment falls between these assessments. However, he requests a valuation of the subject at $2,125,220. We note this value is the subject's assessed value set in 2019, which remained the value through 2022. (Ex. A, p.12). The Board of Review submitted a narrative exhibit list which explained the valuation changes for hotels near the subject property. It also submitted eight comparable hotel properties and noted, "the hospitality industry uses per hotel room as a unit of comparison when they are marketed." (Exhibit list and Ex. D). The subject's value per room is $38,723, which the Board of Review contends is "in line when compared to other similar class hotels in the area." The following table summarizes eight properties the Board of Review submitted that it believes demonstrates the subject is equitably assessed. (Ex. D). Address Year Built Gross Building Area (GBA) (SF Room Count 2023 Assessed Value AV AV/GBA AV/Room Subject — 4025 McDonald Dr (Baymont Inn) 1986 36,262 80 $3,097,800 $85 $38,723 A — 1315 Associates Dr(Country Inn 2000 42,304 69 $3,340,600 $79 $48,414 B - 1275 Associates Dr Main Stay Inn 2000 45,375 75 $3,033,300 $67 $40,444 C — 3100 Dodge St Best Western 1978 117,755 150 $8,164,900 $69 $54,433 D — 4055 McDonald Dr(Quality Inn 1990 23,436 52 $1,732,600 $74 $33,319 E — 2080 Holiday Dr(Holiday Inn Express 2008 47,682 87 $4,802,400 $101 $55,200 F — 3400 Dodge St Fairfield Inn 1992 25,235 56 $2,158,000 $86 $38,538 G — 3434 Dodge St Hampton Inn 1975 58,999 97 $5,711,900 $97 $58,886 H — 2730 Dodge St Super 8 1986 20,852 61 $1,686,400 $81 $27,646 The subject property is at the lower end of the range in gross building area. As a general rule, all else being equal, a smaller property will have higher per unit values than larger properties. 3 We also note that although most of the sales are dated (between 2015 and 2022), there are no time adjustments, or any other adjustments to the sales to account for differences that may exist when compared to the subject. Comparables A and B are those Patel identified on AM Hotels' petition. Their assessments per room are higher, although their total assessment are similar. These properties are newer, have larger gross building area, but fewer rooms. According to the Board of Review's exhibit, they are similar in quality (grade) to the subject but their condition is unknown. Comparable A sold in 2018 for $2,715,000 and Comparable B sold in 2017 for $1,880,000. Nothing is known about the sale transactions. Comparable C is the only property that sold in 2022 for $12,036,000. While it is larger, older, and better quality than the subject, its assessed -value -to -sale -price ratio is 0.68, which suggests it is assessed for less than market value. However, again the record contains no information about the sale, and without information about whether the sale was an arm's-length transaction or contained personal property, we cannot rely on it for an indication of the subject's market value. This property's assessment also increased by 94.5% after its sale. Considering the record as a whole, and the lack of other information, the data presented by the Board of Review indicates is that the subject's assessment is in line with other similar hotel properties, whether based on the total assessment or per room valuation. Analysis & Conclusions of Law AM Hotels claims the subject property's assessment was not equitable as compared with the assessments of other like property in the taxing district. § 441.37(1)(a)(1)(a). In Iowa, property is to be valued at its actual value. § 441.21(1)(a). Actual value is the property's fair and reasonable market value. § 441.21(1)(b). Market value essentially is defined as the value established in an arm's-length sale of the property. Id. Sale prices of the property or comparable property in normal transactions reflecting market value, and the probable availability or unavailability of persons interested in 12 purchasing the property, shall be taken into consideration in arriving at its market value. Id. If sales are not available to determine market value then "other factors," such as income and/or cost, may be considered. § 441.21(2). There is no presumption the assessed value is correct, but the taxpayer has the burden of proof. §§ 441.21(3); 441.37A(3)(a). The burden may be shifted; but even if it is not, the taxpayer may still prevail based on a preponderance of the evidence. Id.; Compiano v. Bd. of Review of Polk Cnty., 771 N.W.2d 392, 396 (Iowa 2009) (citation omitted). When the taxpayer "offers competent evidence that the market value of the property is different than the market value determined by the assessor, the burden of proof thereafter shall be upon the officials or persons seeking to uphold such valuation." Iowa Code § 441.21(3). To be competent evidence, it must "comply with the statutory scheme for property valuation for tax assessment purposes." Soifer v. Floyd Cnty. Bd. of Review, 759 N.W.2d 775, 782 (Iowa 2009) (citations omitted). In this case, AM Hotels retains the burden of proof. To prove inequity, a taxpayer may show an assessor did not apply an assessing method uniformly to similarly situated or comparable properties. Eagle Food Centers v. Bd. of Review of the City of Davenport, 497 N.W.2d 860, 865 (Iowa 1993). Alternatively, a taxpayer may show the property is assessed higher proportionately than other like properties using criteria set forth in Maxwell v. Shivers, 133 N.W.2d 709, 711 (Iowa 1965). The Maxwell test provides inequity exists when, after considering the actual and assessed values of similar properties, the subject property is assessed at a higher proportion of its actual value. Id. This is commonly done through an assessment/sales ratio analysis comparing prior year sales (2022) and current year assessments (2023) of the subject property and comparable properties. However, to succeed in an equity claim, more than one property must be analyzed. Miller v. Property Assessment Appeal Bd., 2019 WL 3714977 (Iowa Ct. App. Aug. 7, 2019). AM Hotel's primary contention is that the subject's assessed value increased at a higher rate than comparable properties. We have long noted however, it is insufficient to simply compare the subject property's assessed value to the assessments of other properties or the rate of change of property assessments to demonstrate inequity. 5 Further, as previously noted, variation in sizes — whether gross building area or room counts — explains much of the difference in the per unit assessed values and does not demonstrate inequity. In the present case, AM Hotels provided no evidence that different methods were applied to similarly situated properties. Nor did it provide any recent sales, which are necessary to calculate an assessment -to -sales -price ratio as provided in Maxwell. The Board of Review's evidence included only one sale from 2022; however, we lack information to determine whether this was arm's-length and moreover, more than one comparable is necessary for an equity claim. Considering the only evidence in the record, the subject property's assessment falls within the range of other hotels in the area. Viewing the record as a whole, we find AM Hotels has failed to prove the subject property is inequitably assessed. Order PAAB HEREBY AFFIRMS the City of Dubuque Board of Review's action. This Order shall be considered final agency action for the purposes of Iowa Code Chapter 17A. Any application for reconsideration or rehearing shall be filed with PAAB within 20 days of the date of this Order and comply with the requirements of PAAB administrative rules. Such application will stay the period for filing a judicial review action. A Any judicial action challenging this Order shall be filed in the district court where the property is located within 30 days of the date of this Order and comply with the requirements of Iowa Code section 441.37B and Chapter 17A. Elizabeth Goodman, Board Member Karen Oberman, Board Member Dennis Loll, Board Member Copies to: Sonny Patel by eFile City of Dubuque Board of Review by eFile 7