Fraughton v. Utah State Tax Comm'n
2019 UT App 6
| Utah Ct. App. | 2019Background
- In 1973 Fraughton purchased an abandoned brick church and 2.41 acres in South Jordan for use as his residence and studio.
- For 2015 the County assessed the Property at $1,163,780; Fraughton protested, claiming fair market value of $704,480.
- The Salt Lake County Board of Equalization reduced the assessment to $947,000; Fraughton appealed to the Utah State Tax Commission.
- Before the Commission Fraughton offered no appraisal or comparable sales; the County submitted an appraisal valuing the Property at $725,700 (land ≈ $724,155; building $1,500).
- Fraughton claimed an oral 1973 City promise rezoned the Property to a purported "Rural Mix" use, which he argued should limit value; City records showed RM meant Residential Multi‑Family since at least 1987.
- The Commission set value at $725,700; Fraughton sought judicial review challenging the valuation and raising a constitutional argument about accounting for "non‑intrinsic human values."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commission erred in fair market valuation | Fraughton argued the Property should be valued lower based on an alleged 1973 zoning promise ("Rural Mix") | Commission relied on County appraisal and City zoning evidence (RM = Residential Multi‑Family) | No error: Commission's valuation is supported by evidence and was within its authority |
| Whether Fraughton met his burden to obtain a lower valuation | Fraughton claimed error in assessment and relied on his 1973 zoning claim instead of submitting valuation evidence | County presented an appraisal; Fraughton submitted no comparable sales or appraisal | Held for defendant: taxpayer must show error and provide a sound evidentiary basis for a lower value; Fraughton failed both prongs |
| Whether Commission should resolve alleged historical zoning/spot‑zoning | Fraughton contended City orally agreed to spot‑zone the Property in 1973 as Rural Mix, grandfathering restrictive use | City records showed RM = Residential Multi‑Family since at least 1987; Commission’s role is valuation, not adjudicating municipal zoning disputes | Court refused to disturb Commission; oral, uncorroborated 1973 claim insufficient to show Commission erred |
| Whether valuation method violated state/federal constitutions by ignoring "non‑intrinsic human values" | Fraughton argued fair market valuation is unconstitutional and fails to account for historic/aesthetic values | Respondents relied on established fair market valuation practice and statute; brief inadequately developed | Court declined to reach the merits because Fraughton inadequately briefed the constitutional claim |
Key Cases Cited
- Atlas Steel, Inc. v. Utah State Tax Comm'n, 61 P.3d 1053 (Utah 2002) (standards for appellate review of Commission findings and law)
- Utah Ry. Co. v. Utah State Tax Comm’n, 5 P.3d 652 (Utah 2000) (taxpayer must show error and provide sound evidentiary basis for lower valuation)
- Utah Power & Light Co. v. Utah State Tax Commission, 590 P.2d 332 (Utah 1979) (taxpayer cannot obtain reduction without submitting an alternative valuation subject to scrutiny)
- Palazzolo v. Rhode Island, 533 U.S. 606 (U.S. 2001) (zoning and regulatory restrictions are relevant to fair market value)
- University Heights, Inc. v. State Tax Comm'n, 364 P.2d 661 (Utah 1961) (Commission’s supervisory role in ensuring equalized property values rather than micromanaging local appraisals)