Docket No. 03-22636.001-C-3 & 04-21196.001-C-3
10 of 16
The PTAB finds that the best evidence of the subject's market
value for 2003 and 2004 are the LaSalle Appraisal Group, Inc.,
Summary Reports of Complete Appraisals for both of the years at
issue. The intervenor, for the year 2003, did not provide any
independent valuation evidence or a witness of its own to
estimate an alternative market value as of the assessment date at
issue. Moreover, the Board finds the intervenor's only witness,
Dost, did not successfully refute the testimony or value
estimates of Ryan, the taxpayer's appraisal witness. Similarly,
the board of review did not present any witnesses to provide
testimony in support of its current assessments or the reports
submitted into evidence for valuation purposes in an attempt to
uphold the current assessments. The Board finds the board of
review reports, without any independent testimony, of little
weight.
The appellant provided the PTAB with complete appraisal reports
for each year and the PTAB was also provided with the testimony
of the author of these appraisals. Ryan further provided the
PTAB with a complete description of the subject premises and
explained he performed a thorough interior and exterior
inspection of the subject. His testimony and his report provide
the PTAB with a complete description and analysis of both the
subject property and its market value.
Ryan performed an income approach and a sales comparison approach
to value in arriving at his estimate of market value. Ryan gave
most weight to the sales comparison approach. Ryan did not
consider the cost approach to value based on his contention that
buyers and sellers of properties such as the subject do not look
to this approach. The witness testified that buyers and sellers
of large anchor stores in malls deal on a national market. Their
primary consideration is the stabilized retail sales of the
store. All of the sales comparables used by Ryan in his 2003 and
2004 reports are anchor department stores, with the exception of
the Kohl's comparable found in the 2003 report. Ryan adjusted
for necessary factors in determining his market value findings.
The PTAB finds Ryan explained on several occasions the method of
his analysis, and, generally such adjustments are considered by
definition as qualitative adjustments.
In each appraisal, Ryan estimated the subject's market value at
$47.50 per square foot. The witness further testified there were
no significant changes to the property between 2003 and 2004.
Ryan testified that the trend among department stores such as the
subject was a decline in retail sales. In fact, the data in the
record indicated the subject's retail sales declined from 2003 to
2004.
