Kimbrough v. Idaho Board of Tax Appeals
150 Idaho 417
| Idaho | 2011Background
- Kimbroughs purchased a 0.66-acre segment exempt from taxation due to public right-of-way, leaving 14.76 subject to assessment.
- Farm use focused on alfalfa; just over two acres contain outbuildings and the home.
- County exempted 13.76 acres under I.C. § 63-604 and taxed the remaining acre, including the home, at market value.
- 2002–2006 assessments were stable; 2007 total assessment nearly doubled, attributed mainly to the homesite and residential improvements.
- Kimbroughs appealed to the Canyon County Board of Equalization and the Idaho Board of Tax Appeals, both affirming; district court conducted a de novo trial upholding the county valuation.
- District court held the Homesite valuation at market value was proper and not arbitrary or discriminatory.
- Kimbroughs argued § 63-604 should exempt homesites contiguous with agricultural land; respondents argued exemption applies only to land actively devoted to agriculture; regulations define homesite separately and not exempt.
- Attorney fees sought under I.C. § 12-117(1) were denied on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the agriculture exemption extends to homesites contiguous with farmland. | Kimbroughs contend homesite should qualify under § 63-604. | Respondents hold homesite not exempt under § 63-604. | Homesite not exempt; § 63-604 applies to actively devoted agricultural land only. |
| Whether the homesite valuation was arbitrary or discriminatory. | Kimbroughs claim excessive valuation; rely on comparables. | County used sales-comparison method with appropriate comparables. | Valuation not manifestly excessive or discriminatory; supported by substantial evidence. |
| Whether attorney fees are recoverable on appeal. | Seek fees under I.C. § 12-117(1). | statute does not authorize fees on appeal from agency decision. | Fees denied; statute not applicable. |
Key Cases Cited
- Merris v. Ada Cnty., 100 Idaho 59, 593 P.2d 394 (1979) (Idaho Supreme Court 1979) (burden to show manifestly excessive or discriminatory valuation; presumes correctness of appraisal)
- Ada Cnty. Bd. of Equalization v. Highlands, 141 Idaho 202, 108 P.3d 349 (2005) (Idaho Supreme Court 2005) (land must be actively used for agriculture to qualify for exemption)
- Ada Cnty. Bd. of Equalization v. Roeder Holdings, L.L.C., not provided in text (—) ((cited for interpreting agricultural exemptions))
- Canty v. Idaho State Tax Comm'n, 138 Idaho 178, 59 P.3d 983 (2002) (Idaho Supreme Court 2002) (ambiguous tax provisions construed against taxpayer; general principle of exemptions)
- Bradon Bay, Ltd. P'ship v. Payette Cnty., 142 Idaho 681, 132 P.3d 438 (2006) (Idaho Supreme Court 2006) (administrative rule interpretation given weight in tax assessments)
- Hayden Lake Fire Prot. Dist. v. Alcorn, 141 Idaho 307, 109 P.3d 161 (2005) (Idaho Supreme Court 2005) (statutory interpretation and burden considerations in tax cases)
- Idaho Power Co. v. Idaho State Tax Comm'n, 141 Idaho 316, 109 P.3d 170 (2005) (Idaho Supreme Court 2005) (valuation standards and reliance on market value)