In the Massachusetts court case, what happened after the expert assumed a selling price 10% less than the asking price, and then adjusted for the differences in square footage to arrive at his opinion?

• A. The board refused abatement and was upheld by an appellate board
• B. The appellant won full relief
• C. The case was dismissed
• D. The court ordered a new appraisal

Answer: (A)

When evaluating an appraisal for a tax abatement, the credibility of the value hinges on whether the starting point and the subsequent adjustments are grounded in market data. In this case, the expert began with a selling price 10% below the asking price and then adjusted for differences in square footage to reach a value opinion. If that starting point isn’t supported by credible market evidence and the size adjustments aren’t clearly justified by actual market data (how price changes with size in comparable sales), the resulting opinion can be seen as unfounded.

The board’s decision to deny the abatement, and the appellate board’s affirmation of that denial, shows that the courts will uphold a determination when the appraisal relies on a questionable initial price and unsubstantiated adjustments. The lesson is that adjustments must be market-based and well-documented; otherwise, the value opinion is unlikely to justify relief on appeal.