Assessment Comparables to Include the Region or Area Where the Property is Located
In Ilankamban v. Township of Pittsfield,Michigan Court of Appeals, No. 303113, March 13, 2012, the Michigan Tax Tribunal did not commit an error of law when it stated that there was no requirement that the true cash value (TCV) of a taxpayer's residential property be calculated for property tax assessment purposes using comparables located in the same neighborhood as the property. In support of its assessment, the township submitted sales evidence comparing the taxpayer's property to comparable parcels located in adjacent neighborhoods. The taxpayer argued that TCV must be calculated by using comparables located within the property's immediate neighborhood.
The Michigan Court of Appeals held that, contrary to the taxpayer's argument, the place where the property is at the time of assessment does not refer only to the property's immediate neighborhood. Rather, the place where the property is at the time of assessment should be understood more broadly to include the region or area where the property is located. Therefore, when the sale-comparison or market approach is used to determine TCV, an assessor is required to make adjustments based on the property's location. The need to make adjustments for location presupposes that an assessor be allowed to use comparables not necessarily within the property's immediate neighborhood.