In a recent decision, the Appeals Court of Massachusetts reviewed a decision from the Tax Board affirming the plaintiffs’ property valuation as determined by the local board of assessors. In Sliski v. Bd. of Assessors of Lincoln, 45 N.E.3d 612 (Mass. App. Ct. 2016), the plaintiffs owned two parcels of land, a larger parcel of over 4.5 acres used for agricultural purposes, and a small parcel of just less than one acre upon which the plaintiffs’ residence was located. The plaintiffs had previously received an agricultural exemption for the large parcel twenty-five years ago. However, in calculating the assessment, the local board of assessors applied a multiplier of 9.00 to the value of $7.20 per square foot for the small parcel. This resulted in an appraisal of the small parcel at a rate of over $2.8 million per acre. The plaintiffs challenged the assessment, arguing that it did not accurately reflect the value of the small parcel, nor the value of the land as a whole due to the agricultural exemption.
On appeal, the court found that the Board did not appear to have considered the methodology in reviewing the town’s valuation of the small parcel. The court was particularly concerned by the use of the 9.00 multiplier. The court noted that the town’s residential land valuation document stated that a factor of 1.00 should be applied to property within the neighborhood in which the small parcel is located. Further, the document did not include a factor of 9.00 for any property, as the highest factor listed was 1.91. The court therefore could not affirm a decision by the Board that did not appear to consider the Massachusetts statute requiring that all land occupied by a dwelling be valued, assessed, and taxed by the same standards as other taxable property.