Bailey Seed Farms, Inc. v. State Bd. of Tax Comm'rs

In Bailey Seed Farms, Inc. v. State Bd. of Tax Comm'rs, 542 N.E.2d 1389, 1392 (Ind. Tax Ct. 1989), the Court held that the State Board's final determination, finding the taxpayer-seed company liable for property tax on inventory in its possession on the date of assessment, was not supported by substantial evidence. Id. The assessment was made after the State Board considered and accepted the claim of a second seed company that it did not own the seeds in question. The State Board relied upon the hearing officer's recommendation in making its determination; however, the record was silent as to the basis for this recommendation. Upon remanding the case to the State Board, the Court observed that the State Board "failed to submit any evidence to the court establishing a reasonable basis for its subsequent assessment against the taxpayer-seed company." Id.