Assessment Appeals Committee - Microsoft...property located at 4125 Albert Street in the City. In...

DETERMINATION OF APPEALS UNDER Section 216 of The Cities Act

Appeal Number: AAC 2013-0065 et al Date and Location: May 8, 2014 - Regina, SK

Tanias Holdings Ltd. et al (See Schedule A)

As represented by Altus Group Limited

Appellant

- and –

City of Regina

Respondent APPEARED FOR: The Appellant: Archie Fieldgate, Altus Group Limited (Altus) Deana Puff, Altus

Leonard D. Andrychuk, Q.C., MacPherson Leslie & Tyerman LLP The Respondent: Gerry Krismer, Assistant City Assessor Jayne C. Krueger, Legal Counsel, City Solicitor’s Office HEARD BEFORE: John Eberl, Panel Chair

Lorna Cottenden, Member Peter Stroh, Member Lise Gareau, Director

Assessment Appeals Committee

APPEAL AAC 2013-0065 et al. INTRODUCTION: [1] The Assessment Appeals Committee (the Committee) has received an appeal from the

decision of the Board of Revision (the Board) for the City of Regina (the City) pursuant to Section 216 of The Cities Act (the Act), regarding the assessed value of a retail strip-mall property located at 4125 Albert Street in the City. In its decision dated June 4, 2013, the Board confirmed the assessed value for the property as determined by the Assessor at $1,357,500 for the year 2013 and dismissed the appeal with respect to all issues. The Board, the Appellant and the Respondent agreed prior to the commencement of the Board hearing that all evidence and arguments from that appeal, and the decision of the Board, would carry forward and apply to appeals against 48 additional properties identified in the Board’s decision. Prior to the Committee hearing, seven properties were formally withdrawn from appeal by Altus, leaving a total of 42 properties under appeal including the lead property described above.

[2] The role of the Committee is not to redo the Board’s hearing. Rather, the Committee is

to review the evidence from that hearing and determine whether the Board came to the proper conclusion in rendering its decision. If the Committee concludes that the Board did not come to the proper conclusion based upon the evidence before it, the Committee is then required to do what the Board ought to have done. The onus is on the Appellant to demonstrate to the Committee where the Board erred.

ISSUES: [3] a) Did the Board err when it ruled that copies of “Income SPSS Detail Report(s)” (SPSS

Reports) and “Field Sheet Report(s)” (Field Sheets) be removed from the official record of the Board, and that Altus could refer to the material from the other documents in their submission and make oral arguments?

b) Did the Board err when it confirmed the assessed value for the subject property? c) Did the Board err in finding that the assessed value for the subject property

achieved equity and met the market valuation standard? DECISION: [4] The Committee determines that the Board erred with regard to Issue [3]a) described

above. Copies of the SPSS Reports and Field Sheets ought to have been accepted by the Board as part of Altus’ written submission and should have formed part of the official record of the Board hearing.

APPEAL AAC 2013-0065 et al. [5] The Committee determines that the Board did not err with regard to Issue [3]b). The

Committee finds based on its review of the evidence from the Board hearing that the Appellant failed to provide proof of error in the Assessor’s work.

[6] The Committee determines that the Board did not err with regard to Issue [3]c). The Appellant failed to provide proof that the assessed value calculated by the Assessor did not achieve equity and meet the market valuation standard.

FACTS: [7] The content of the Board’s record is attached as Appendix “A”.

[8] At the commencement of the Committee hearing, the parties concurred that Appeal No.

2013-0065 respecting the property legally described as Lot 1A, Block F, Plan No. 64R02963, Extension 0, with civic address of 4125 Albert Street, in the City of Regina, would be the lead appeal and that the hearing would focus on the subject property. The parties agreed that the decision of the Committee would carry forward and apply to all the properties identified in Schedule A below.

[9] The properties under appeal and their respective assessed values, confirmed by the

decision of the Board, are as follows: Schedule A

Number AAC

Appeal Number

BOR Appeal

Number Property Owner

Account Number

Civic Address Taxable

Assessed Value

1 2013-0065 **

2013-27342

Tanias Holdings Ltd. **

10012315 4125 Albert Street ** $1,357,500

2 2013-0006

2013-27285

1010 Pasqua St N Real Estate Holdings

Ltd. 10087728

1010 N. Pasqua Street

$1,503,600

3 2013-0007

2013-27288

Mid City Centre Corp. 10163123 1450 Broad Street $3,322,000

4 2013-0008

2013-27291

Discovery Properties Inc.

10040181 2035 Park Street $5,960,200

5 2013-0009

2013-27297

Kolitsas Holdings Inc. et al

10007322 803 Argyle Street N. $1,444,000

6 2013-0010

2013-27298

101073674 Saskatchewan Ltd.

10022097 907 Albert Street $3,315,500

7 2013-0011

2013-27299

Investors Group Trust Co. Ltd.

10022096 921 Albert Street $5,251,200

8 2013-0012

2013-27290

Andros Enterprises Ltd.

10037722 1945 Victoria

Avenue $957,000

APPEAL AAC 2013-0065 et al.

9 2013-0013

2013-27292

Kalamaki Properties Inc.

10052974 2606 - 28th Avenue $1,419,800

10 2013-0013

2013-27294

Kalamaki Properties Inc.

10052973 4030 Albert Street $761,100

11 2013-0014

2013-27295

H & H Holdings Inc./Joelric Holdings

Inc. 10054870 4440 Albert Street $2,443,700

12 2013-0015

2013-27286

Kensington Village Holdings Ltd.

10064937 107 Albert Street $3,296,900

13 2013-0016

2013-27289

RB3 Properties Inc. 10070201 1601 - 4th Avenue $5,378,100

14 2013-0016

2013-27296

RB3 Properties Inc. 10121922 6175 Rochdale

Boulevard $1,670,200

15 2013-0016

2013-27317

RB3 Properties Inc. 10032556 1929 Albert Street $658,900

16 2013-0018

2013-27293


10040677 2815 E. Quance

Street $7,288,400

17 2013-0049

2013-27302

Real Prairie Properties Inc.

10033856 100 Victoria Avenue $1,575,400

18 2013-0049

2013-27311


10007970 1802 - 9th Avenue N. $1,465,400

19 2013-0049

2013-27351


10002028 5934 Rochdale


20 2013-0050

2013-27303

TRIF Holdings Ltd. 10087726 1055 N. Stockton

Street $2,103,900

21 2013-0050

2013-27321

TRIF Holdings Ltd. 10036869 2124 Albert Street $1,999,300

22 2013-0051

2013-27304

Harvard Developments Inc.

10054056 1101 Kramer


23 2013-0051

2013-27307


10050961 1350 - 23rd Avenue $884,700

24 2013-0051

2013-27340


10069971 3698 E. Victoria

Avenue $4,167,800

25 2013-0051

2013-27345


10166365 4504 Gordon Road $7,872,900

26 2013-0051

2013-27346


10166364 4600 Gordon Road $9,842,500

27 2013-0051

2013-27347


10173567 4601 Gordon Road $5,337,500

28 2013-0051

2013-27348


10154463 4800 Gordon Road $7,071,500

29 2013- 2013- Melcor 10047440 166 University Park $6,854,500


0052 27309 Developments Ltd. Drive

30 2013-0052

2013-27331

Melcor Developments Ltd.

10017124 2601 Avonhurst

Drive $15,111,000

31 2013-0054

2013-27313

MIC Properties Inc. 10034752 1832 E. Victoria

Avenue $6,918,200

32 2013-0054

2013-27338

MIC Properties Inc. 10012315 318 N. Albert Street $3,795,600

33 2013-0057

2013-27324


10037922 2201 Broad Street $877,600

34 2013-0059

2013-27328

Whiterock Victoria and University

Regina Inc. 10040664

2550 E. Quance Street

$4,834,800

35 2013-0059

2013-27332



2660 E. Star Lite Street

$6,473,400

36 2013-0059

2013-27355



685 University Park Drive

$3,021,200

37 2013-0061

2013-27334

Quance Equities Inc. 10040670 2810 E. Quance

Street $5,873,900

38 2013-0061

2013-27337

Quance Equities Inc. 10040680 3115 E. Quance

Street $2,540,200

39 2013-0062

2013-27335

Victoria Gate Equities Inc.

10070076 3010 E. Quance

Street $3,087,900

40 2013-0063

2013-27336

Gardiner Joint Venture Ltd.

10044483 302 University Park

Drive $5,380,700

41 2013-0064

2013-27339

Normanview Crossing Inc.

10010076 350 N. McCarthy


42 2013-0068

2013-27352

Sunset Steak House Ltd.

10023068 6300 Dewdney

Avenue $1,237,100

** Denotes lead appeal. [10] The base date for determining assessed values of non-regulated properties for the years

2013 to 2016 is established as January 1, 2011, in accordance with Saskatchewan Assessment Management Agency (SAMA) Board Order made pursuant to section 12(1)(d) of The Assessment Management Agency Act and dated July 8, 2010. No market data that occurred on or after December 31, 2010, except where a property owner’s fiscal year occurs on or before May 31, 2011, shall be used to determine assessed values during the years noted (SAMA Board Order dated December 16, 2009). All the properties are classed as Commercial; therefore, the taxable assessment of each property is 100% of the assessed value as set out in sections 12 and 13 of The Cities Regulations (the Regulations).

APPEAL AAC 2013-0065 et al. [11] The subject property for the lead appeal is a single-storey strip mall located for assessment

purposes in Neighbourhood 1542 – Hillsdale in the South Albert commercial district of the City. The building houses both office and retail tenants. Basic property characteristics and quality/condition ratings of the Assessor are as follows:

[12] The grounds of appeal to the Committee as stated by Altus are:

“1. The Board erred by ruling on a matter outside its jurisdiction on an agreement made between the City and the Appellant. Specifically, the inclusion of Addenda 2 in the Appellant’s written submission and denying its use. The Appellant indicated the confidentiality agreement did not preclude the use of the SPSS Reports and Field Sheets in the Appeal. Denying its use interfered with natural justice and right of a fair appeal hearing. The City also did not object in its 10 day submission to the materials be entered as evident.

2. The Board erred in its finding that there was “no evidence that the Assessors failed to achieve equity in the assessment”, whereas equity is achieved by applying the market value standard so that the assessments bear a fair and just portion of the market value of similar properties.

3. The Board erred in its finding that the stratification based on primary property type or usage, rather than potential income, risk and cap rates will “not necessarily result in assessments that bear a fair and just portion of the market value of similar properties”. Thus, also not speaking to the evidence and issue of the comparable sales used to value the subject. Also, implying all properties are purchased for the same investment purpose and viewed by the market entirely the same.

4. The Board erred in its finding that the assessment met the “standards” contemplated by Section 163 (f.1) (iv) of the Cities Act.

5. The Board erred in its finding that the assessment represented market value.” [13] On April 8, 2014, the Committee received from Altus a submission totaling 64 pages, which

was labeled Exhibit AAC-A1 at the hearing. On April 16, 2014, the Respondent hand-delivered a 69-page submission to the Committee, which bears the date March 14, 2014, and was labeled Exhibit AAC-R1.

Lot Size 18,707 square feet Building Size - Main Floor Gross Area 7,884 square feet Wall Height 14 feet Year Built & Effective Year Built 1985 Number of Units 5 Exterior Finish Brick Veneer On Site Parking Paved Property Quality Rating Good Property Condition Rating Average

APPEAL AAC 2013-0065 et al. [14] During the Committee hearing, Mr. Andrychuk submitted Committee decisions for Appeal

No. 2009-0095 (Invest Nominee I Ltd. v. Prince Albert [City]) and Appeal No. 2009-0127 (Confed Shopping Centre Inc. v. Saskatoon [City]). This evidence was accepted and labeled as Exhibit AAC-A2 and Exhibit AAC-A3, respectively. During its oral submissions to the Committee, Altus brought forward that a document referring to the “Multiple Cap Rate Issue” (11 pages in length) had been submitted to the Board and discussed at the hearing. The Committee notes that the face page of the document shows a ‘received’ stamp bearing the date April 3, 2013, while the Board hearing occurred on April 24 and 25, 2013. This document had not been transmitted to the Committee by the Board as part of the record of the hearing. Both Altus and the Respondent concurred that the material had been before the Board at the hearing (page 359 of the transcript). The Committee accepted that the document should have formed part of the Board record, but marked the evidence as Exhibit AAC-A4 to ensure that it would be recognized in the Committee record. Also during the hearing, the Respondent tendered a single Committee decision for appeal numbers 2011-0005 to 2011-0012, inclusive, Appeal No. 2011-0037 and Appeal No. 2011-0041 (Various Property Owners v. Regina [City]), which was accepted and marked as Exhibit AAC-R2.

Issue No. [3] a) Did the Board err when it ruled that copies of SPSS Reports and Field Sheets be removed from the official record of the Board but that Altus could refer to the material from other documents in their submission and make oral arguments? BACKGROUND: [15] As part of its 20-day submission to the Board, Altus submitted detailed information on each

of 58 properties stratified and analyzed by the Assessor in determining the 7.85% Cap Rate used to calculate the assessed value for the subject property and the 41 additional properties under appeal (identified as “Addenda 2” at Tab 2.c.iii. of the Board record). For each property, the following was submitted:

• Photographs of each property reproduced from Internet sites and specifically from the

City website. The Cap Rate for the property was denoted on the page containing the lead photograph for each of the properties.

• SPSS Reports and Field Sheets generated from the City’s Tax and Assessment Suite software. The Field Sheets had been redacted. Information masked included the names of the owner(s) of the property and the amount shown under the heading “Last Sale”.

• Property and Assessment Tax Summary and a property map reproduced from the City website.

APPEAL AAC 2013-0065 et al. [16] As part of discussing preliminary matters at the Board hearing, Altus requested that the

SPSS Reports and Field Sheets submitted be ordered as confidential by the Board (section 202 of the Act). The Respondent objected to copies of that information being accepted as part of Altus’ submission. The objection was based on letters of agreement that the Respondent had prepared pursuant to section 202(1)(b) of the Act (Tab 2.h. of the Board record) following two separate written requests - one dated January 22, 2013, and one dated February 1, 2013 - from Altus for SPSS Reports and Field Sheets of “… properties … used in the development of the 2013 Global Retail Model.” The letters of agreement, bearing the dates January 28, 2013, and February 12, 2013, signed by both Altus and the Respondent, contain an opening paragraph summarizing the request, as well as other information under these headings: “Information to be Provided to Altus”, “Fees for Information” and “Confidentiality and Proprietary Rights”. The paragraph under the latter heading is shown below:

“The Reports the City provides to Altus remain the property of the City of Regina and are provided to Altus for Altus’ exclusive use for the preparation of assessment appeals to the 2013 City of Regina Board of Revision. Altus shall not sell or copy the Reports the City provides to Altus without the prior, written consent of the City of Regina.”

[17] The transcript of the Board hearing (Tab 2.i. of the Board record) details the proceedings with regard to this issue at pages seven through 25, inclusive. The entire transcript is 408 pages in length.

[18] The Board ruled on the matter immediately following a brief conference among the panel

members. In its written decision, the Board summarized its conclusion on page 3:

“… the SPSS Reports and Field Sheets in Addenda 2 were copied in violation of the agreement between the Appellant and the City of Regina. The Board noted that the information was requested for the purpose of conducting possible assessment appeals and decided that the information contained in the reports and field sheets could be used by the Appellant and referred to in his submission and oral arguments on the appeal. The Board ruled pursuant to Section 202(1) of the Act that the property photographs contained in Addendum #2 be allowed and that all other documents in Addendum #2 be removed from the official record of the Board of Revision with the proviso (emphasis added, word is italicized in the original decision) that the Agent may refer to the material from the other documents in their submission and oral arguments.”

[19] Prior to any submissions from the parties at the Committee hearing, Mr. Andrychuk stated

that he would only be speaking to the issue described above and requested that argument and all submissions respecting the issue be heard in full before moving on to the valuation issues. The parties were in concurrence with the request. The Committee ruled that the hearing proceed on that basis.

APPEAL AAC 2013-0065 et al. POSITIONS OF THE PARTIES: [20] Position of the Appellant:

a) The Committee has ruled in the past that the Assessor has a duty to provide information to an appellant that is relevant to the appeal. Failure to do so constitutes the denial of a fair hearing (Exhibit AAC-A3 is cited).

b) The Committee has also previously held that sections 201 and 202 of the Act deal adequately with matters of confidentiality (Exhibit AAC-A2 is cited).

c) Restricting the use of information directly pertaining and relevant to an appeal as the Board has done compromises the principles of natural justice and procedural fairness.

d) In its 10-day submission to the Board, the Respondent did not raise any objection to the inclusion of the SPSS Report and Field Sheets by Altus in its 20-day submission (i.e., the information had already been submitted to the Board with a copy to the Respondent). This constitutes “a waiver of any objection” or “an implied consent to their use”. Also, the Respondent raised the matter at the beginning of the Board hearing during canvassing for preliminary matters without forewarning, which both ambushed Altus and put the Board in the difficult position of attempting to rule on a procedural objection on the spot. The result was a confusing decision suggesting that Altus could refer to the information orally but not submit it, as it would not form part of the record. This made it very difficult for Altus to put forth its case to the Board (appeal numbers 2011-0013 to 2011-0036, inclusive, and appeal numbers 2011-0038 to 2011-0040, inclusive, Regina [City] v. Cityview Properties Ltd. et al is cited).

e) The letter of agreement signed by Altus and the Respondent allows Altus to use the information “… for the preparation of assessment appeals to the 2013 City of Regina Board of Revision....” That statement implies that copies of the information can be included in written submissions made by Altus.

f) The Board does not have the jurisdiction to decide a matter of interpretation of an agreement – that is a matter better dealt with civilly, by the courts (Domtar v. Prince Albert, 2011 SKCA 151 is cited).

g) Even if the Board had jurisdiction to rule on the issue, any restriction on the copying of materials relevant to an appeal contravenes the Act. Therefore, the ruling made by the Board constitutes an “impingement of the appeal process” and forced Altus into “an untenable position”.

h) Information relevant to an assessment or an assessment appeal cannot be withheld from an appellant, and the ruling of the Board effectively precluded Altus “… from tendering necessary evidence to support its appeal.” As a result, the Appellant was denied the right to a fair and open hearing (Nortel Networks Inc. v. Calgary (City), 2008 ABCA 370 is cited).


i) An alleged breach of an undertaking agreement does not render materials relevant to an appeal inadmissible at a hearing or to a Board of Revision generally (Ferenczy v. MCI Medical Clinics, 2004 CanLII 12555, Ontario Supreme Court and Cam v. Hood, [2006] B.C.J. No. 1255 (B.C.S.C.) are both cited).

j) Sections 171(6)(b) and 201(1)(b) of the Act both imply that copies of confidential information may be used and submitted for an appeal hearing – that is reasonable. It is also reasonable that the Respondent may seek to restrict the use and copying of confidential information relevant to a specific appeal from being used for an unrelated appeal or in another jurisdiction, or for other purposes. The Act does not state that confidential information cannot be copied for the appeal hearing for which it was requested and imposing such restriction is not reasonable.

k) The position put forth by the Respondent that Altus “… could have asked for permission [to submit the SPSS Reports and Field Sheets] at the Hearing but … chose not to …” (Exhibit AAC-R1, paragraph 76) is “disingenuous”. Had the Respondent been sincere about the position, they could have made the point to the Board that permission had not been requested by Altus, but then allowed the information to be submitted.

l) Exhibit AAC-R2, submitted and discussed at the Committee hearing, is not relevant to this appeal for two reasons. Firstly, the wording of the “Confidentiality and Proprietary Rights” clauses in the Respondent’s current letter of agreement differs from the wording used in the disclosure agreement discussed in AAC-R2 (paragraph 4 is cited). The agreement discussed in AAC-R2 prohibited entirely any copying of the information “… without the consent of the City of Regina.” Secondly, the issue at hand in AAC-R2 was the use of information beyond the appeal for which it was requested, which is not the case in this appeal.

[21] Position of the Respondent:

a) The Assessor has the right to restrict the use of information pursuant to sections 171(5)(b) and 201(1)(b) of the Act (paragraphs 14, 18 and 20 of Exhibit AAC-R2 are cited). This includes the right to restrict reproduction of any such information.

b) The issue at hand is not a matter of confidentiality, nor the misuse of confidential information. The issue is that Altus reproduced the SPSS Reports and Field Sheets for the properties without the “… prior, written consent …” of the Respondent as required by the letter of agreement. Thus, Altus is in breach of that agreement.

c) Altus has breached the conditions attached to the release of confidential information in the past and such information has appeared in submissions for appeals other than the one for which it was originally requested. The Respondent’s actions in attempting to restrict the abuse of the confidential information by Altus are, in part, in response to past breaches of the conditions imposed by the Respondent.


d) Altus obtained the SPSS Reports and Field Sheets it requested and made use of that information to prepare for the appeal. Additionally, the Board allowed Altus to refer to the evidence orally at its hearing. The Respondent did not at any time deny Altus access to the evidence. As well, the Respondent did not object to Altus tabulating the information and submitting the information in that form to the Board. Therefore, the Appellant was not denied a fair hearing.

e) Altus could have asked permission from the Respondent to copy the documents, even as late as at the Board hearing, but did not. The Respondent has never refused permission to an appellant to copy confidential information for the purposes of an appeal if such permission is properly requested. However, that permission is not intended to allow an appellant to copy such information electronically; that is, not store the evidence in an electronic database for unlimited use or access.

f) Nothing in sections 171 or 201 of the Act prohibit the Respondent from imposing the conditions contained in the letter.

ANALYSIS AND REASONS: [22] Sections 201 and 202 of the Act provide the legislative framework for matters of

confidentiality regarding assessment appeals, in terms of the provision of information. Subsection 201(1) is of particular note and is reproduced below:

“201(1) Before providing information to the assessor or any other party to an appeal, the party that is to provide the information may: (a) Declare the information confidential; and (b) seek an undertaking of the party that: (i)all or some of the information provided is provided solely for the

purpose of preparing an assessment or for an appeal hearing; and (ii) no other use may be made of the information.”

[23] Altus’ letters (dated January 22, 2013, and February 1, 2013, at Tab 2.h. of the Board

record) requesting the “non-client” SPSS Reports and Field Sheets for properties whose sales data was used by the Respondent to develop the 2013 Global Retail Model, both include the following paragraph:

“The above requested data will be used by Altus solely for the purpose of conducting possible assessment appeals. Copies of such data may form part of the written submissions to Regina’s Board of Revision. If this be the case, Altus will treat such data as being “confidential” in nature.”

[24] The Respondent’s letters of agreement sent to Altus in response to the requests do not

address the matter of confidentiality even though one of the headings in the letter reads “Confidentiality and Proprietary Rights”. The paragraph under that heading, reproduced above, only addresses proprietary rights but not confidentiality.

APPEAL AAC 2013-0065 et al. [25] This issue began with Altus, as a preliminary matter at the Board hearing, requesting

that the information be declared confidential, even though it was redacted information. The Respondent raised objection at that time, as noted from an excerpt from page 12 of

the Board hearing transcript, where the Respondent said “… I would suggest that they [Altus] have, in fact, broken the agreement, and these reports would not properly be before this Board, and we would ask that those reports not be considered by the Board.”

[26] The Committee concurs with the position of the Respondent that the issue from its

point of view is one of breach of conditions or breach of contract, but not one of confidentiality. Altus did not contravene any confidentiality requirements set out in the Act and followed through with its written promise to the Respondent to treat the data received as confidential. However, the Committee also concurs with Mr. Andrychuk that matters such as alleged breach of contract should be left to the courts to decide. Administrative tribunals legislatively empowered with hearing assessment appeals must restrict themselves to dealing with those issues as such. The Respondent claims that the conditions of its letter of agreement had been breached by the physical copying of the confidential data provided to Altus. A court may consider the position of the Respondent along with the position of Altus and additionally consider the legality of the contract itself pertaining to legislation and case law, among other matters, prior to making a decision. But it is not, and was not, a matter for the Board to rule upon regardless of whether or not the Respondent raised it.

[27] The Committee further notes that there is no restriction on copying information,

confidential or not, contained in the Act. Section 171 deals with the provision of information to the Assessor for assessment purposes. 171(1) affords the Assessor the right to “… request any information or document that relates to or might relate to the value of any property …” It follows that some of such information may be deemed confidential, whether it be sensitive financial documents or individual/personal privacy or other. Sections 201 and 202 then address the matter of confidentiality. No restriction on copying is made or authorized in these sections of the Act, nor anywhere else in the Act.

[28] Section 202(3) of the Act reads as follows:

“No order declaring information to be confidential pursuant to this section prevents full disclosure of that information on an appeal to the appeal board or to the Court of Appeal.”

In his submission to the Committee at the hearing, Mr. Andrychuk referred to the

Board’s ruling as creating a “conundrum” for Altus and that it put Altus in an “untenable position”. Given the absence of restrictions on copying in the Act and the direction of


202(3) noted above that no confidentiality order shall prevent “full disclosure” of information to an appeal board, it seems nonsensical to the Committee that the Board ruled that Altus could refer orally to the material but could not submit copies of it for its own reference or the Board’s reference. The ruling by the Board even put itself in a position of being unable to verify tabulated and orally-referenced information and documents. That position is certainly not the intended outcome of the legislation, nor of procedural fairness generally.

[29] In his initial presentation of argument to the Committee, Mr. Andrychuk orally

referenced the “Cityview Properties” decision, being Committee Appeal No. 2011-0022 as lead appeal for a number of appeals. This decision bears the date June 5, 2013. The Committee finds paragraphs 78 and 79 to be of relevance in this appeal. These paragraphs speak to the matter that an appeal should be heard and decided on its merits, rather than derailed or confused by procedural or jurisdictional objection that is unwarranted. An excerpt from paragraph 78 seems particularly relevant to this appeal:

“… The parties to assessment appeals are entitled to have decisions affecting their rights and interests made using a fair, impartial and open process. If we take too narrow of an approach to the legislative requirements for appeal procedures and/or the case law interpreting the same, we run the risk of appellants with substantive issues and concerns not having their arguments heard. When this happens, the assessment appeals system fails.”

[30] As noted above, the Committee determines that the Board erred with regard to this

issue. Copies of the SPSS Reports and Field Sheets ought to have been accepted by the Board as part of Altus’ written submission and should have formed part of the official record of the Board hearing.

Issue No. [3] b) Did the Board err when it confirmed the assessed value for the subject property? BACKGROUND: [31] The subject property (and all other properties under appeal) was valued via the income

approach. The basic steps the Assessor follows in determining assessed values via the income approach for Commercial properties are as follows:

a) Estimate the market rent per square foot of rentable building area. b) Apply the estimated market rent to the rentable area of the building. c) Estimate the market rent for parking and apply to the number of parking stalls. d) Add the building space rent and parking rent. This sum is the Total Rent. e) Estimate the market vacancy per cent. f) Estimate the vacant space shortfall per cent (i.e., the operating expenses for vacant


space). g) Convert the vacancy and vacancy shortfall percentages into dollar amounts. h) Deduct the vacancy and vacancy shortfall dollar amounts from the total rent. This

yields the Net Income. i) Determine the market capitalization rate (Cap Rate) through analysis of sales of

comparable properties. j) Divide the Net Income by the Cap Rate. This calculation yields the assessed value for

the property. The lower the Cap Rate, the higher the resulting assessment. For example, a 10% Cap Rate yields an assessed value that is 10 times the Net Income, while an 8% Cap Rate yields an assessed value that is 12.5 times the Net Income.

[32] Determining the Cap Rate through analysis of sales of comparable properties (see [31](i) above) involves the classification of properties into groups with similar physical characteristics and similar value-driven characteristics. In order to achieve equity, the objectives of the classification process are to allow the calculation of assessed values for large numbers of properties efficiently under the system of mass appraisal; stratify properties into classes so that comparisons are meaningful; provide a definition of each class that ensures sufficient numbers to establish valuation parameters; and, determine large enough classes so that similar properties are assessed similarly. The classification process involves six basic steps as described below (Respondent’s submission to the Board at Tab 2(d) of the Board record):

a) Identify valuation parameters. b) Collect appropriate data. c) Analyze collected data. d) Develop guidelines for applying valuation parameters. e) Apply valuation parameters. f) Test results.

[33] In determining the Cap Rate to be applied to determine the assessed value of the subject

property, the Assessor first developed eight “net rent” models for commercial properties in the City, being Auto Dealerships, Hotel/Motel, Office, Parkade, Parking, Retail Enclosed Shopping Centres, Retail Global and Warehouse. The subject was categorized in the Retail Global model.

[34] Within the Retail Global model, the Assessor first considered 158 general commercial sales

that occurred in the appropriate time period (see above). Thirty five of those sales were removed from consideration, as they had a calculated Cap Rate of either less than 5% or greater than 15%. The Assessor then analyzed (Multiple Regression Analysis or MRA) and performed statistical testing on the remaining 123 sales and developed five stratifications with five separate Cap Rates applied. The strata and Cap Rates developed by the Assessor


are shown below along with a breakdown of the number of property sales in each strata (under the heading “Count”), the result of the Assessment to Sales Ratio (ASR) statistical test and the Coefficient of Dispersion (COD) statistical test for each group (page 13 of Altus’ submission to the Committee):

Strata Cap Rates Count ASR COD

Light Industrial Manufacturing Buildings built 1970 or newer 5.98% 8 1.000 14.0%

Single-Story properties built 1970-1999 Properties built in 2000 and newer Light Industrial Manufacturing buildings Pre1970

7.85% 58 0.999 20.5%

Single-Story properties Pre1970 9.50% 34 1.001 20.4%Multi-Story properties built 1970-1999 10.44% 8 1.000 18.9%Multi-Story properties built Pre1970 11.32% 15 1.000 19.3%Overall 123 1.000 19.8%

[35] The property groupings were finally tested using statistical tests such as the Mann-Whitney

(M-W) test and the Kruskal-Wallis (K-W) test. These tests further prove relationships exist or do not exist between pairs of property groupings (M-W test) or among more than two property groupings (K-W test). The test results confirmed that the stratification shown above met the statistical parameters associated with the tests.

[36] The main valuation issues in this appeal are the manner in which the Assessor classified the

properties into groups in order to determine applicable Cap Rates and the resulting 7.85% Cap Rate applied to calculate the assessed value.

POSITIONS OF THE PARTIES: [37] Position of the Appellant:

a) The Assessor erred in stratifying the 123 properties, based on their sales data, into groups based on the physical characteristics of the building(s) located on the properties such as year built, number of storeys or deemed to be “Light Industrial Manufacturing” buildings. Rather, the stratification should have been performed by grouping properties based on similar building/property use. Specifically, three characteristics “… did not appear to be relied upon by the Assessor …” and should have been considered, namely number of units, quality rating and type of building (See Tab 2.c., page 16 of Altus’ 20-day submission to the Board). The Assessor’s stratification implies that all properties are purchased for similar investment purposes and viewed by the market entirely the same. That implication is incorrect.


b) Rather than the subject property and all properties under appeal (42 in total) being subject to the Retail Global Model Cap Rate of 7.85%, as the Assessor has done for 2013, Altus proposes Cap Rates for those properties as set out below, based on stratifying the properties according to similar building/property use:

Strata Cap RatesNeighbourhood Shooping Centres/Retail Strip Malls 9.03%Retail Stores 10.12%Restaurants 9.04%

c) The Market Value Assessment in Saskatchewan Handbook (the Handbook) adopted

by SAMA includes a section entitled “Valuation Parameters Guide”. In that section, valuation parameters are defined as “… the property characteristics determined through market analysis to influence value for a group of properties as of a given base date”. In discussing the question “What are the variables or factors in a valuation process?” the Handbook states as follows (see Tabs 1-3, inclusive of Addenda I at Tab 2.c.ii. of the Board record):

“The market value based assessment of every type of property is guided by and relates to a number of common characteristics or variables: 1. The physical characteristics of the property:

• Property use; • Building size/area; • Construction style/material; • Condition of improvements; • Building configuration; • Site size, and; • Location.

2. The supply and demand conditions in the market place. 3. Legal restrictions (i.e. zoning, etc.).”

As property use is the first physical characteristic listed, it should be the first and primary characteristic considered in stratifying groups of properties during the valuation process. Thus, the Assessor erred in not grouping the properties according to property use first and then statistically testing the data to ensure compliance.

d) The 58 sales analyzed to calculate the 7.85% Cap Rate used to value the properties under appeal is “… not a homogenous grouping” (Tab 2.c., page 15). Altus points out that the majority of the sales were not Neighbourhood Shopping Centres (i.e., retail stores with greater than one unit). 24 of the 58 sales had property uses identified by Altus as either “Industrial Flex Buildings” or “Industrial Light Manufacturing Buildings”, while only five of the sales were Neighbourhood Shopping Centres.


e) The starting point in using sales data for valuation purposes is to array properties into comparable groups. If this is not done, referring to the Handbook for guidance, valuation results will be skewed. The Assessor erred at this point as the original stratification of the properties did not result in the grouping of comparable properties.

[38] Position of the Respondent:

a) Altus failed to prove to the Board that the Assessor erred in valuing the properties via standard appraisal practices and failed to prove to the Committee that the Board erred in fact or law in rendering its decision.

b) Altus never alleged that any of the properties involved in the 123 commercial sales analyzed by the Assessor are not “Strip Commercial” properties as defined in the Strip Commercial Valuation Guide section of the Handbook (see pages 81 and 82 at Tab 3 of Addenda 1 of Altus’ submission to the Board). Therefore, it is assumed that the grouping is correct.

c) The Respondent quoted the following excerpt from the Handbook (same reference as above):

“… From an assessment point of view, the critical element affecting the value of a strip commercial property is the income generating potential of the real estate.”

It follows that the use of physical characteristics of a property such as year built, number of storeys, etc. to group properties in order to establish pertinent Cap Rates is the proper way to calculate an equitable value comparable to market value and to achieve the market valuation standard. The use of a property (property use) can change over time or from owner to owner; however, that factor should not affect the value of the property. Therefore, the Assessor’s grouping of the properties according to physical characteristics in order to calculate assessed values is correct.

d) The Respondent referred to another excerpt from the same section of the Handbook (Strip Commercial Valuation Guide – see page 90 of Addenda 1 of Altus’ submission to the Board) under the subheading “Classify Properties into Homogeneous Groups”, as shown below:

“Strip commercial properties can be stratified based on the types of properties

prevalent in the jurisdiction and/or market area. There is no one correct or appropriate classification system [emphasis added].”


This is indicative that the Assessor, therefore, is afforded some discretion, subject to analysis and statistical testing, in the stratification of properties into groups. While Altus, or any other appellant or agent may propose different stratification and achieve a different Cap Rate as a result, and that result could also be analyzed as comparable and fall within statistical testing parameters, it does not invalidate the Assessor’s work or prove that it was incorrect.

e) Scott Miller, Manager of Assessment Research with the City of Regina – Assessment Division, was qualified by the Board as an expert witness in the areas of mass appraisal and statistical analysis of capitalizations and rents (see page 5 of the decision of the Board at Tab 2.j. of the Board record). Mr. Miller’s analysis and statistical testing of the 123 sales (at Tab 2.d.A-1. of the Board record) showed that Altus’ proposed sales groupings and Cap Rates fell outside of acceptable parameters and that the Assessors were within acceptable parameters (testimony begins at page 216 of the Board hearing transcript).

f) Altus did not treat the sales data of the properties consistently in stratifying the properties into groups for the purpose of establishing Cap Rates, but rather, arrayed the sales in a manner to suit its needs. At the Committee hearing, the Respondent referred to pages 10 and 11 of AAC-R1 and stated of Altus’ proposed alternate Cap Rates, “It was cherry picking at its finest.” Additionally, Altus’ proposal that Cap Rates be applied to each building on a property with multiple buildings located on it based on building use is not equitable (pages 12 to 17, inclusive of AAC-R1).

ANALYSIS AND REASONS: [39] At the Committee hearing, Altus reviewed its submission to the Board, highlighting

points that it believed were significant in showing where the Assessor may have erred in stratifying the properties as he did, and in explaining its own proposed re-stratification of the 123 properties according to primary building use in order to develop alternate Cap Rates for the 42 properties under appeal. Altus explained that it not only statistically tested and verified its own proposed models, but had also tested the Assessor’s models to ensure that its testing produced similar results which its testing confirmed.

[40] Altus’ proposed alternate stratification according to primary building use required data

from just 28 of the 123 sales available to produce categories that encompassed the primary building use of all the properties under appeal. The remaining 95 properties of the group were labeled as “Other General Commercial”. Altus stated at the Committee hearing that no further stratification was proposed for that group as Cap Rates for all the appealed properties were already developed. The alternate stratification proposal, including ASR and COD testing results, is tabulated below (from Tab 8, Page 172 of Addenda I of Altus’ submission to the Board):


Strata Cap

Rates Count ASR COD

Retail 10.12% 10 1.00 19.85% Neighbourhood Shopping Centres 9.03% 14 1.00 22.54% Restaurants 9.04% 4 1.00 11.67% Other General Commercial 8.48% 95 1.00 24.43% Overall 123 1.000 23.43%

[41] The Respondent pointed out, and the Committee concurs that it is significant to note,

that Altus’ stratification of the 123 sales produces an overall COD of 23.43% while the Assessor’s produces a result of 19.8%. From a statistical analysis perspective, the lower result is better – the Assessor’s calculated assessed values for the appealed properties would be closer to actual selling prices than Altus’. While this does not entirely invalidate Altus’ strata, it provides further evidence that the Assessor’s stratification is credible.

[42] Altus provided the Board with a wide range of statistical analysis results and

comparisons, which in its view, proved that its analysis showed that the 58 sales used by the Assessor required further stratification and that its proposed stratification provided acceptable statistical results. Statistical testing employed by Altus included calculating the ASR and COD for properties and groups of properties. Altus also applied the M-W and K-W test to pairs or groups of properties, where applicable. An explanation of the tests was provided to the Board at Tab 14 of Addenda 1 of Altus’ 20-day submission to the Board.

[43] At the Committee hearing, the Respondent stated that much of the M-W and K-W

statistical testing performed by Altus was unreliable as those tests call for an overall sample of greater than 20 sales or units, and that each individual sample have a size of greater than nine sales or units, in order to produce the most reliable results. Some of the tests performed by Altus did not meet those criteria. Mr. Miller had testified that same caution to the Board (starting at page 251 of the transcript) at its hearing. Both Mr. Miller at the Board hearing (pages 221-297 or the transcript) and the Respondent at the Committee hearing painstakingly ensured that the Assessor’s processes were understood by panel members. Whether or not the Respondent’s criticism of the reliability of Altus’ M-W and K-W testing is warranted may be subject to question and interpretation of statistical parameter theory. Regardless of that, Altus did not dispute the Respondent’s testing results.

APPEAL AAC 2013-0065 et al. [44] The Handbook does provide guidance to the Assessor in establishing valuation

parameters to be used in a mass appraisal system. Property use happens to be first listed in setting out the physical characteristics that may be considered in stratifying properties; however, nothing in the Handbook suggests that this characteristic be applied first or that it has ranking or precedent over characteristics such as building size, building configuration, or some combination of characteristics. That is the purpose of tools such as regression analysis and the reason to statistically test the results of that analysis – to find appropriate stratification that provides acceptable results. Additionally, the Handbook is a guide and does not have the force of law; therefore, the Assessor is guided by its principles, but those principles do not have the same precedent as if set out in legislation.

[45] At the Committee hearing, Altus pointed out that the use of one of the 58 properties

whose assessment data had been provided by the Respondent had changed and that Altus had not been made aware of such change. The Respondent countered that the property use must have changed since the data was either prepared or had been transmitted to Altus; it was not the job of the Respondent to notify Altus that a change in property use had occurred. The Committee notes that this example provides support for the Respondent’s position that property use may change over time, or from owner to owner, particularly with commercial/retail properties. Thus, the Assessor’s use of such characteristics as age of building and building configuration (number of storeys) to eventually calculate the “income generating potential” (see 39(c) above) of the subject is not incorrect.

[46] As part of its summation of argument to the Committee, the Respondent concluded by

referencing Laing (Regina (City) v. Laing Property Corp. 1994 SKCA 4690), Sasco (Sasco Developments Inc. v. Moose Jaw (City), 2000 SKCA 90), Bison Properties (Bison Properties Ltd. v. Regina (City), 2008 SKCA 158) and Estevan Coal (Estevan Coal Corp. v. Estevan (Rural Municipality No. 5), 2000 SKCA 82). The Respondent pointed out that the referenced case law upholds the principle that the Assessor must be afforded discretion and the right to use personal judgment in valuating properties. Additionally, the cases support that it is incumbent upon the Appellant to prove “… material error of fact, of law, or of assessment principles and practice …” (Laing). If the Appellant fails to prove such error, then assessed values of properties “… should not be interfered with” (Laing). While the Respondent’s position has been articulated many times in the past, it must always be balanced with the right of an appellant to appeal and to be provided with clear and reasonable explanation of the means and methods used to calculate the assessed values of properties. Notwithstanding the foregoing, in this appeal Altus failed to show error in the work of the Assessor to the Board and subsequently failed to show the Committee where the Board erred in evaluating the work of the Assessor. With


respect to this issue, the Committee finds that the Board did not err in rendering its decision and the appeal is therefore denied.

Issue No. [3] c) Did the Board err in finding that the assessed value for the subject property achieved equity and met the market valuation standard? BACKGROUND: [47] Set out below are the pertinent sections of the Act in defining equity and the market

valuation standard:

“163 In this Part: (f.1) “market valuation standard” means the standard achieved when the

assessed value of property:

(i) is prepared using mass appraisal; (ii) is an estimate of the market value of the estate in fee simple in the property; (iii) reflects typical market conditions for similar properties; and (iv) meets quality assurance standards established by order of the agency;

(f.2) “market value” means the amount that a property should be expected to realize if the estate in fee simple in the property is sold in a competitive and open market by a willing seller to a willing buyer, each acting prudently and knowledgeably, and assuming that the amount is not affected by undue stimuli; (f.3) “mass appraisal” means the process of preparing assessments for a group of properties as of the base date using standard appraisal methods, employing common data and allowing for statistical testing;”

165(1) An assessment shall be prepared for each property in the city using only mass appraisal. … (3) The dominant and controlling factor in the assessment of property is equity. … (5) Equity in non-regulated property assessments is achieved by applying the market valuation standard so that the assessments bear a fair and just proportion to the market value of similar properties as of the applicable base date.”

ANALYSIS AND REASONS:

APPEAL AAC 2013-0065 et al. [48] Much of Altus’ testimony and evidence was focused on presentation of an alternate

form of stratification that could be applied to the sales data to calculate different Cap Rates for the properties under appeal, rather than proving gross error in the methodology employed by the Respondent in valuing the properties. There is no doubt that the assessments for the properties were prepared using mass appraisal techniques. The Respondent provided reasonable explanation as to its use of certain physical characteristics of the properties to group them such that the market value of the real estate was properly estimated and that the application of those characteristics provides a strata of properties with similar attributes that is reflective of market conditions.

[49] At page 57 of the Respondent’s submission to the Board (Tab 2.d.A-1.), Mr. Miller

concludes:

“The City of Regina’s model produces better overall equity between various strata groups and better overall dispersion as indicated by an overall COD of 19.8% vs. Altus’s overall COD of 23.4%.

The major flaw with Altus’s model is that it had no provisions in their strata groups to recognize the variance in cap rates between the older and newer properties. The other major flaw is that their model had no provision in the strata groups to account for the obvious difference in cap rates between single-story and multi-story properties. These conclusions are fully supported by the preceding analysis.”

[50] At the Committee hearing, Altus did not dispute this analysis. While the Board’s

decision at pages 7 and 8 do not directly reference this text, the Board finds support for the Respondent’s reasoning, analysis and statistical testing results, and correctly finds that it has achieved equity among the properties under appeal and met the market valuation standard set out in the Act. At the end of its Analysis and Conclusions section on page 8 of its decision, the Board states:

“The assessor also conducted statistical tests which demonstrated that the assessment meets required assurance standards. The evidence shows an assessment to sales ratio (ASR) of 1.00 which is within the required range of 0.95 to 1.05.

The Board concurs with the Appellant that the results of the City’s analysis indicate a “… reasonable performance level”. The Board believes that the evidence demonstrates that the variables the City used to determine the Cap Rate stratifications resulted in assessments that bear a fair and just portion of the market value of similar properties.

Having reviewed the evidence and presentations, the Board has found no evidence that the Assessor failed to achieve equity in the assessment of the subject property …”

APPEAL AAC 2013-0065 et al. [51] The Committee determines that the Board did not err with regard to this issue. The

Appellant failed to provide proof that the assessed values calculated by the Assessor do not achieve equity and meet the market valuation standard.

CONCLUSIONS: [52] For the above reasons, the Committee finds that the Board erred when it ruled that

copies of the SPSS Reports and Field Sheets be removed from the official record of the Board, but that Altus could refer to the material from the other documents in their submission and make oral arguments. The filing fees shall be refunded.

[53] The Committee further finds that the Board did not err when it confirmed the assessed

value for the subject property as prepared by the Assessor and in finding that the assessed value for the subject property achieved equity and met the market valuation standard. The assessed value of the subject property is hereby confirmed at $1,357,500 for the year 2013. The assessed values of all properties under appeal are confirmed as set out in Schedule A above.

Dated at REGINA, Saskatchewan this 20th day of June, 2014.

Saskatchewan Municipal Board – Assessment Appeals Committee

Per: ________________________ John Eberl, Panel Chair

Per: ________________________ Lise Gareau, Director

APPEAL AAC 2013-0065 et al. Appendix “A” Record of the Board:

a. Board Information (letter from board and anything else from the board)

b. Notice of Appeal to the BOR – includes Schedule A with grounds of Appeal and Results of Pre-filing Discussion with Assessor’s Office and Notice of Assessment 2013 Duplicate

c. April 3, 2013 - Appellant’s 20 Day Submission from Altus Group Limited - includes

the following:

i. Appendices:

A. Valuation Parameters Spreadsheet B. Re-stratification Spreadsheets C. Mann-Whitney Statistics Results D. Current ASR of the 14 Sales E. Subject Property Data which includes Tabs 1 to 37

ii. Addenda 1 with the following Tabs:

1. SAMA Handbook, Introduction 2. SAMA Handbook, Valuation Parameters 3. SAMA Handbook, Strip Commercial 4. City of Regina Retail – Global Model 5. Model Information Correspondence with the City of Regina 6. Request for Non-Client SPSS and Field Sheets 7. Altus Current Model ASR and COD Calculations 8. Altus Revised Model ASR and COD Calculations (4 Groupings) 9. Kruskal-Wallis Results 10. ASR Analysis 11. Excerpt from IAA0 Text “Property Appraisal and Assessment

Administration Text” 12. Excerpt from “The Appraisal of Real Estate, Third Edition” 13. Stratification Maps 14. Mann-Whitney and Kruskal-Wallis Tests, Excerpt from “Real Property

Assessment Year Two” iii. Addenda 2 – Global Retail 7.85%, 58 Cap Rate Sales, Property Photos

(September 4, 2013 memo from Board of Revision indicates the property photographs “… are being provided for your information, however, these documents were removed from the official record of the Board of Revision”. The information contained in the documents was allowed to be referred to for oral arguments. Reference 2g for related BOR Order), SPSS and Field Sheets with the following Tabs:


1. 2235 8th Avenue 2. 1355 Lorne Street 3. 145 Hodsman Road 4. 107 Albert Street 5. 127 Hodsman Road 6. 1455 Broad Street 7. 1220 Scarth Street 8. 1808 Cameron Street 9. 1011 Osler Street 10. 1602 Winnipeg Street 11. 1758 McAra Street 12. 1180 Winnipeg Street 13. 1944 McAra Street 14. 1505 Albert Street 15. 505 Broad Street 16. 4371 Albert Street 17. 604 12th Avenue 18. 6175 Rochdale Boulevard 19. 405 Maxwell Crescent 20. 651 Henderson Drive 21. 2275 Broad Street 22. 1106 Winnipeg Street 23. 1350 Lorne Street 24. 1121 E Weaver Street 25. 3419 Pasqua Street 26. 1808 Cameron Street 27. 318 N Albert Street 28. 1324 Hamilton Street 29. 1120 Broad Street 30. 2710 E Quance Street 31. 639 Adams Street 32. 1066 Albert Street 33. 3241 Saskatchewan Drive 34. 2201 Broad Street 35. 1750 McAra Street 36. 1015 Winnipeg Street 37. 1319 Albert Street 38. 1201 Winnipeg Street 39. 2815 Dewdney Avenue 40. 1129 E Weaver Street 41. 1320 St. John Street 42. 225 Quebec Street 43. 1350 Scarth Street 44. 1170 N Stockton Street 45. 1248 McDonald Street 46. 1135 N Lakewood Court 47. 870 Albert Street 48. 1023 N Devonshire Drive


49. 365 Broad Street 50. 1052 Albert Street 51. 1834 Angus Street 52. 1761 Wallace Street 53. 1601 Ottawa Street 54. 2332 Scarth Street 55. 735 Victoria Avenue 56. 20 Hesse Bay 57. 1131 E Weaver Street 58. 141 Hodsman Road

d. April 12, 2013 letter with City of Regina’s 10 Day Submission including the following

Appendices and Tabs: A. Assessor Evidence Package A-1. Additional Assessor Evidence Package B. Copy of Assessment Notice C. Income (SPSS Detail) Report D. Situation Map E. Income and Expense Request Form F. Sales Verification Form G. Market Study H. Excerpts from Assessment/Appraisal Textbooks I. Assessor Qualifications J. Index of Related 2013 Appeal Submissions

e. April 18, 2013 letter with the Appellant’s 5 Day Submission from Altus Group Limited

including the following Appendices: 1. Excerpts, The Appraisal of Real Estate, Third Edition and Real Property

Assessment 2. Excerpt, Real Property Assessment – Mass Appraisal and Single-Property

Appraisal, Chapter 12 3. Excerpts, The Appraisal of Real Estate, Third Edition – Chapter 20 and 22,

the income approach 4. Excerpts – BUSI 344 – Statistical and Computer Applications in Valuation,

Less 4, market identification and characteristics

f. April 19, 2013 Request for Court Reporter and Order for Recording of Hearing

g. April 24, 2013 Board Order with respect to Addenda #2 h. Exhibit IR – January 22, 2013 and February 1, 2013 letters from Altus requesting

Non-client SPSS Reports/Field Sheets i. Transcript of the BOR hearings – April 24, 2013 and April 25, 2013 j. June 4, 2013 BOR Decision with record of the date the decision was received by the

Appellant

Assessment Appeals Committee - Microsoft...property located at 4125 Albert Street in the City. In...

Documents

Transcript of Assessment Appeals Committee - Microsoft...property located at 4125 Albert Street in the City. In...