Equalization Adjustments - Property Assessment In Indiana
As our Supreme Court stated, in order to achieve the uniformity and equality requirement of Article X, 1, property assessment and taxation in Indiana must be "based on property wealth." Boehm v. Town of St. John, 675 N.E.2d 318, 328 (Ind. 1996).
Property wealth is measured through objectively verifiable data. State Bd. of Tax Comm'rs v. Town of St. John, 702 N.E.2d 1034, 1041 (Ind. 1998).
It is appropriate for the State Board to calculate assessments based on true tax value; however, when comparing assessments to determine uniformity, an external unit or standard of measurement must be used -- one which is objectively verifiable.
Our Supreme Court has said that fair market value may well be the standard. See Town of St. John II, 675 N.E.2d at 327.
Insdiana Court believes that fair market value is the standard, and will continue to do so until the State Board rebuts that presumption.
Thus, the use of market value based sales/assessment-ratio studies is an acceptable way, within the context of public utility assessment, to determine whether equalization adjustments are necessary to achieve assessment uniformity.