{¶ 1} The appellant, Timberlake L.P., challenges the value assigned to its real property by the Montgomery County Auditor for tax year 2001. Thе property— identified in the county auditor’s records as parcel number B02-006-01-0063 — is known as the Timberlake Apartments. A 144-unit apartment complex constructed in 2000 is on the property, which covers 9.215 acres of land.
{¶ 2} For tax year 2001, the Montgomery County Auditor fixed the true value of the property at $5,994,310. Timberlake asked the Montgomery County Board of Revision to reduce that valuation, arguing that the рroperty was worth only $3,980,000 that year.
{¶ 3} The board of revision determined that the total value of the property was $4,147,200, which prompted the Board of Education of the Vandalia-Butler City School District to file an appeal under R.C. 5717.01 with the Board of Tax Appeals (“BTA”). The board of education urged the BTA to set the value of the property at the amount originally determined by the county auditor. The BTA held a hearing and concluded that the county auditor’s original valuation of the property was in fact correct, and the BTA therefore reversed the decision of the board of revision and directed the county auditor to again set the value of the property at $5,994,310.
{¶ 4} Timberlake has now appealed to this court. For the reasons that follow, we affirm the BTA’s decision.
{¶ 5} “When cases are appealed from a board of revision to the BTA, the burden of proof is on the appellаnt, whether it be a taxpayér or a board of education, to prove its right to an increase [in] or decrease from the value
{¶ 6} In this case, the board of education argued before the BTA that the decision of the board of revision was not supported by any probative, competent evidence. Timberlake had presented testimony before the board of revision frоm a real-property-tax consultant, and the BTA concluded in its opinion that he was not qualified to offer expert testimony about the property’s value.
{¶ 7} At the hearing before the BTA itself, a state-certified real estate appraiser testified on behalf of Timberlake. That appraiser — Stephen Ewan— calculated a value for the property under three differеnt methods: (1) the income-capitalization approach, which focuses on a property’s capacity to generate income for the owner, (2) the sales-comparison approach, which focuses on the prices of сomparable properties that have changed hands recently, and (3) the cost approach, which focuses оn the cost of replacing the improvements on the property. Ewan relied on all three valuation methods to reaсh his final conclusion, and he appraised the property’s value at $4,000,000.
{¶ 8} The BTA found Ewan’s opinion unconvincing. The comparable properties that Ewan examined in appraising the property were nearly 30 years older than the Timberlake aрartment project, and, according to the BTA, Ewan failed to make “any meaningful adjustments to the sales comparables” tо account for their age. The BTA also described Ewan’s cost-approach analysis as “circular” and charactеrized his income analysis as “unreliable.” Ewan’s appraisal was not “probative” of the property’s value, according tо the BTA, and the BTA found no other evidence supporting the board of revision’s decision to reduce the value of the proрerty from the amount originally set by the county auditor. In the absence of that evidence, the BTA reversed the board of revision’s dеcision and directed that the auditor’s original valuation be restored.
{¶ 9} Timberlake argues in its appeal here that the BTA should not have ruled in the board of education’s favor, given that the board of education was the appellant before the BTA and presented no witnesses or other evidence at the BTA hearing. To be sure, the burden of proof rested on the board of еducation before the BTA, but “[h]ow a party seeking a change in valuation attempts to meet its burden of proof * * * is a matter fоr that party’s judgment.” Snavely v. Erie Cty. Bd. of Revision (1997),
{¶ 10} We hаve explained that the BTA is entitled to “render its own independent decision as to the valuation of the property in issue.” Cincinnati Milacron Indus., Inc. v. Brown Cty. Bd. of Revision (1988),
{¶ 11} Moreover, the BTA was entitled to reject the testimony that Timber-lake’s appraiser offered, for as we have said, the BTA “is not required to adopt the appraisal methodology espoused by any expert or witness.” Hotel Statler v. Cuyahoga Cty. Bd. of Revision (1997),
{¶ 12} In the absence of probative evidence supporting the reduction in value ordered by the board of revision, and in light of thе problems identified by the BTA with the even lower value proposed by the Timberlake appraiser, the BTA’s conclusion that the сounty auditor’s original valuation should be reinstated was not unreasonable. “In the absence of probative evidence оf a lower value,” a county board of revision and the BTA “are justified in fixing the value at the amount assessed by the county auditor.” Salem Med. Arts & Dev. Corp. v. Columbiana Cty. Bd. of Revision (1998),
Decision affirmed.