Decker Lake Ventures, LLC v. Utah State Tax Commission
2015 UT 66
| Utah | 2015Background
- Decker Lake Ventures owned a 5.22-acre parcel with a 41,296 sq. ft. building in West Valley City assessed by Salt Lake County at $4,027,800 (income approach) for 2010; county BOE upheld the assessment.
- Decker Lake appealed to the Utah Tax Commission under Utah Code § 59-2-1006(5)(b), arguing its assessed value deviated more than ±5% from comparable properties and seeking a substantial reduction.
- Decker Lake submitted two spreadsheets of raw assessed values: one listing 90 land parcels and one listing 18 improvements, but offered no expert witness or analysis tying comparables to the subject property.
- The County presented expert testimony explaining valuation methodology, emphasizing that use classification (office, industrial, etc.) affects lease rates and identified nearby office comparables consistent with Decker Lake’s assessment.
- The Tax Commission found Decker Lake’s separate land/improvement presentation questionable, concluded Decker Lake’s comparables were not persuasive (noting differing use classifications), and denied equalization; Decker Lake appealed to this Court.
Issues
| Issue | Decker Lake's Argument | County/Tax Commission's Argument | Held |
|---|---|---|---|
| Whether the Commission lawfully treated use-classification as pivotal to comparability | Commission erred by effectively requiring identical use-classifications for comparables | Use classification affects lease rates and valuation; the County’s expert supported relying on classifications | Court held no legal error; Commission made a fact-intensive comparability determination entitled to deference given the record and lack of taxpayer rebuttal |
| Whether presenting land and improvements separately was impermissible | Commission erred by criticizing separate land/improvement comparables as a methodological bar | Separate presentation was questionable here because combined comparables better support an equalization argument; County’s expert undermined taxpayer’s method | Court held Commission made a mixed, fact-intensive credibility call, not a legal rule, and gave deference; no reversible error |
| Whether Commission’s factual findings (zoning, overlap of comparables, numeric summaries) were erroneous and prejudicial | Several factual findings were incorrect (zoning, overlap, median/mean, requested reduction amount) and affected outcome | Even if some findings erred, alternative valid bases (use-class differences, lack of taxpayer testimony) support the result; any errors were harmless | Court found substantial evidence for key findings; acknowledged minor errors (zoning, some numbers) but deemed them harmless and affirmed |
| Whether Decker Lake’s failure to present expert testimony doomed its appeal | Taxpayer argued raw assessed-value data should suffice without expert testimony | Without expert analysis to rebut County’s valuation methodology, the Commission properly relied on County expert; taxpayer’s counsel cannot testify | Court affirmed that in this complex valuation context, taxpayer’s failure to proffer expert testimony was fatal to its equalization claim |
Key Cases Cited
- Murray v. Utah Labor Comm’n, 308 P.3d 461 (Utah 2013) (standards for appellate review of agency legal determinations)
- Manzanares v. Byington (In re Adoption of Baby B.), 308 P.3d 382 (Utah 2012) (framework for reviewing mixed law–fact questions and deference analysis)
- Emp’rs Reinsurance Fund v. Labor Comm’n, 289 P.3d 572 (Utah 2012) (harmless error and prejudice in administrative appeals)
- T-Mobile USA, Inc. v. Utah State Tax Comm’n, 254 P.3d 752 (Utah 2011) (applying harmless-error standard in tax commission review)