State Board of Equalization affirms administrative judges in five tax appeals; appellants raise evidence and process concerns

The Tennessee Board of Equalization on Aug. 11 affirmed the initial decisions of administrative judges in five separate tax appeals brought from county boards of equalization, the board announced after hearing brief oral arguments.

The petitions came from property owners and taxpayers who had appealed county valuation decisions to the state board. The board heard limited oral argument (three minutes per side where requested) on several matters and then voted to adopt the administrative judges’ findings as the board’s decisions.

Roland Baggett, representing himself in Baggett v. Davidson County Assessor’s Office (tax year 2021), argued the administrative judge made procedural and evidentiary errors, including allowing testimony from an assessor employee who had not been disclosed as an expert and failing to address what Baggett described as the assessor’s reliance on mass-appraisal software. Baggett told the board, “they have delegated the entirety of their duties to software,” and said the assessor’s property photograph for his home dated to 2015 and did not reflect later work.

Sam Keane, assistant metropolitan attorney representing the Davidson County assessor’s office, responded that the assessor was not required to offer a contingent value and defended the office’s use of computer-assisted mass appraisal systems, saying the taxpayer “failed to put forth any sort of evidence… that would give the ALJ any reason to change the assessment” and that the administrative judge found the assessor’s comparables more compelling.

After hearing both sides, a board member moved to confirm and adopt the administrative judge’s decision; the board recorded a unanimous roll-call vote to affirm the ALJ’s findings in the Baggett case.

The board also heard virtual argument from Wesley Vaughn, the registered agent representing Bethany Realty LLC, which had appealed Davidson County assessments for a skilled-nursing facility for multiple tax years (2021–2024). Vaughn argued the administrative judge improperly credited the assessor’s income-based valuation and used unsupported assumptions including an 8% capitalization rate and market rents not documented for Tennessee. Vaughn asked the board to reverse or modify the initial decision. Brooke Thompson, representing the Davidson County Assessor’s Office, said the assessor provided proper market data and that the ALJ considered a deed of trust exceeding $16 million as supporting evidence.

The board voted unanimously to affirm the ALJ’s decision in Bethany Realty LLC v. Davidson County Assessor’s Office.

In Mary, Queen of Angels, Inc. v. Davidson County Assessor’s Office (skilled-nursing facility appeals for tax years 2021–2024), Vaughn argued the administrative judge applied an incorrect mathematical procedure when adjusting depreciation and relied on unsubstantiated soft-cost and entrepreneurial-profit assumptions. Brooke Thompson replied that the ALJ’s adjustments and acceptance of soft costs were consistent with accepted appraisal practices and the evidence in the record. The board unanimously affirmed the ALJ’s findings.

Two additional appeals with no speakers present — Kasai North America, Inc. v. Coffee County Assessor’s Office (tax year 2023) and Michael Huddleston v. Dixon County Assessor’s Office (tax year 2024) — were presented by board staff summaries. In Kasai, the ALJ found the appellant failed to support a nonstandard valuation for tangible personal property. In Huddleston, the ALJ upheld assessment of 7.8 acres the taxpayer had not shown was included in a prior green-belt application and noted the taxpayer may submit a new green-belt application for the full tract. The board moved to adopt the ALJ findings in both matters and recorded unanimous votes.

Votes at a glance - Baggett v. Davidson County Assessor’s Office (2021): Board affirmed ALJ; unanimous roll call adopting ALJ findings. - Bethany Realty LLC v. Davidson County Assessor’s Office (2021–2024): Board affirmed ALJ; unanimous roll call. - Mary, Queen of Angels, Inc. v. Davidson County Assessor’s Office (2021–2024): Board affirmed ALJ with unanimous roll call. - Kasai North America, Inc. v. Coffee County Assessor’s Office (2023): Board adopted ALJ findings; unanimous roll call. - Michael Huddleston v. Dixon County Assessor’s Office (2024): Board adopted ALJ findings; unanimous roll call. The ALJ clarified the taxpayer may reapply for green-belt status for the full tract.

The board limited oral argument in some matters to three minutes per side, as permitted by board practice. Several appellants raised concerns about evidentiary standards, the use of computer-assisted mass appraisal systems and the adequacy of supporting data for assessor valuations; the counties’ representatives told the board they relied on accepted appraisal methodologies and records in the administrative record. The board’s actions adopt the administrative judges’ findings as the board’s final decisions, which concludes the board-level review and allows parties to pursue any next-step appeals permitted by law.