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Public commenter warns shorter reappraisal cycles could reduce sales-ratio studies
Summary
A public commenter told the Tennessee State Board of Equalization that counties shifting to two- and three-year reappraisal cycles may result in years without required sales-ratio studies, potentially raising compliance concerns tied to earlier federal litigation that spurred the studies.
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Mister Scruggs, appearing virtually before the Tennessee State Board of Equalization, urged the board to consider how some counties’ moves to shorter reappraisal cycles could reduce how often sales-ratio studies are performed.
Scruggs, who said he is with the law firm Evans & Petree and represents thousands of Tennessee taxpayers, told the board he has been following county reappraisal-cycle changes and believes the Division of Property Assessments (DPA) does not perform a sales-ratio study in a county’s reappraisal year. He said that if a county moves to a three-year cycle the DPA typically would not perform a sales-ratio study in the reappraisal year or the following year, and that a two-year cycle could lead to extended periods without any sales-ratio study.
"In a 2 year cycle, the first year, the reappraisal year, the DPA does not do a sales ratio study. The second year, the presumption is that the ratio is the same as the reappraisal year," Scruggs said. "I was involved in the federal litigation that was the origin of the sales ratio studies by the state board. I think this might be problematic… I would ask all to think about that, especially the 2 year situation."
Scruggs named counties he had observed moving to shorter cycles during his remarks, including Blount, Sullivan and Davidson, and asked the board to consider whether the pattern he described could leave counties without a sales-ratio study for multiple consecutive years. He did not present documentary evidence at the meeting; DPA staff did not take action in response during the public-comment period.
The board did not take action on the comment during the meeting; the agenda moved to routine approvals following public comment.
Scruggs’s remarks referenced the historic role of sales-ratio studies in Tennessee, noting federal litigation historically prompted the state to require periodic ratio studies; he urged the board and DPA staff to consider whether shorter county reappraisal cycles create unintended gaps in those studies.
No formal motion or board directive resulted from the comment. The board’s docket continued with staff presentations and routine roll-call approvals later in the meeting.

