Tax Court – Sufficiency of Findings

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Relators sought certiorari review of the Minnesota Tax Court‘s determination of the fair market value on the January 2, 2007; January 2, 2008; and January 2, 2009, assessment dates for an office building. At trial, the tax court heard expert testimony from relators’ appraiser and Ramsey County’s appraiser. After trial, the County submitted a post-trial brief that argued for higher property valuations than the market values assigned to the property by either appraiser. The court then adopted, verbatim, the County’s proposed market valuations on the three assessment dates. The Supreme Court held that when the Tax Court adopts, verbatim, the value determination proposed in a party’s post-trial brief, and that proposed value is lower or higher than the appraisal testimony presented at trial, the court must explain its reasoning for rejecting the appraisal testimony and adequately describe the factual support in the record for its property value determination. Reversed and remanded.

A11-1014 444 Lafayette, LLC v. County of Ramsey (Tax Court)

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