Supervisor of Assessments of Montgomery County v. Lane, 112 A.3d 952

Ann Lane owned unit 1003, a 10th-floor condominium in Parc Somerset (Chevy Chase); Supervisor of Assessments notified her of a $2,130,000 assessment effective January 1, 2011 (date of finality).
Lane and other Somerset House unit owners administratively appealed; the local Appeals Board refused to consider sales after Jan 1, 2011, reduced assessments for units 703 and 803 but left 1003 unchanged; Lane appealed to the Maryland Tax Court.
At Tax Court, the Supervisor’s appraiser relied on three Parc Somerset sales from May 2011 (post–date of finality) as comparables and adjusted for floor premium/size; Tax Court reduced unit 1003’s assessment to $2,075,000.
Lane sought judicial review in the Circuit Court, which held the Tax Court erred by using post–Jan 1, 2011 sales and found the Tax Court’s result arbitrary and capricious relative to reductions for 703 and 803; the circuit court remanded for reconsideration and reduction.
The Court of Special Appeals reviewed the Tax Court decision directly (de novo review of administrative decision), focusing on whether post–date-of-finality sales may be considered and whether the Tax Court’s valuation was supported by substantial evidence.
The appellate court reversed the circuit court and affirmed the Tax Court: post–date-of-finality sales may be considered if reasonably close and otherwise comparable; the Tax Court’s use of those sales was supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tax Court may consider sales occurring after the date of finality to value property as of that date	Lane: statute and purpose prohibit using post–date sales because value must be based on market data before Jan 1, 2011; considering later sales is retroactive	Supervisor: statute requires valuation as of the date but does not bar considering relevant comparable sales shortly after that date when no prior comparables exist	Court: Post–date-of-finality sales are admissible if reasonably close in time and otherwise comparable; statute does not prohibit their consideration
Whether Tax Court’s valuation was arbitrary/capricious and violated uniformity where adjacent stacks received reductions but unit 1003 did not	Lane: disparity with units 703/803 and reliance on post–date sales made the Tax Court’s result arbitrary and a uniformity/Article 15 problem	Supervisor: Tax Court weighed all evidence, used appropriate comparables and appraisal methodology; weight of evidence is for the Tax Court	Court: Tax Court’s decision was supported by substantial evidence and its weighing of comparables was within its expertise; not arbitrary or unconstitutional

Montgomery County Board of Realtors, Inc. v. Montgomery County, 287 Md. 101 (1980) (ordinance valuing property on transfer date conflicted with date-of-finality principle)
Supervisor of Assessments v. Stellar GT, 406 Md. 658 (2008) (distinguishing reassessment issues during three-year cycle from ordinary assessments)
Hance v. State Roads Comm’n of Md., 221 Md. 164 (1959) (admissibility of comparable sales before and after valuation date in condemnation context)
Fields v. Supervisor of Assessments, 255 Md. 1 (1969) (weight to be accorded valuation factors is for Tax Court)
Samet v. Supervisor of Assessments, 290 Md. 357 (1981) (prior neighboring assessments are not a basis for relief)
Comptroller of Treasury v. Science Applications Intern. Corp., 405 Md. 185 (2008) (review of Maryland Tax Court decisions and standards)
Consol. Coal Sales Co. v. State Dept. of Assessments, 382 Md. 439 (2004) (Tax Court decisions overturned for lack of substantial evidence or legal error)