Riverside Development Co. v. Vandenberg

Summary

The Idaho Supreme Court affirmed ad valorem tax valuations of Riverside Development Company’s unsold subdivision lots for tax years 1996 through 1998. The court held that the assessor appropriately considered the lots’ actual and functional use and properly valued them using individual retail values rather than an aggregate wholesale valuation. The court also held that Riverside failed to show by clear and convincing evidence that the assessor’s valuations were manifestly excessive, arbitrary, or otherwise erroneous.

Holdings

1. The Assessor's valuation complied with Idaho Code section 63-208 because the actual and functional use of Riverside's lots was considered, and the district court's finding that the lots were used as single-family residential lots was supported by substantial, competent evidence.
2. The Assessor properly valued Riverside's unsold lots individually using the retail values of comparable lots, and Riverside failed to prove by clear and convincing evidence that the assessments were manifestly excessive, arbitrary, capricious, erroneous, discriminatory, or otherwise prejudicial to substantial rights.

Questions Presented

1. Whether the Assessor considered the actual and functional use of Riverside's unsold subdivision lots as required by Idaho Code section 63-208.
2. Whether the Assessor's individual retail-value assessment of the unsold lots was impermissibly excessive or otherwise erroneous for ad valorem tax purposes.

Disposition

affirmed