Kimbrough v. Idaho Board of Tax Appeals, 150 Idaho 417

Summary

The Idaho Supreme Court affirmed the assessment of the Kimbroughs' homesite at market value and held that a homesite contiguous with agriculturally exempt land is not itself exempt under Idaho Code section 63-604 unless it is actively devoted to agriculture. The court also concluded that the County's valuation was not arbitrary, oppressive, or discriminatory and denied the request for attorney fees.

Holdings

1. A contiguous homesite is not exempt under Idaho Code section 63-604 unless the homesite itself is actively devoted to agriculture. The statute's reference to the total area of land, including the homesite, concerns eligibility for the acreage threshold and does not exempt the homesite itself.
2. The County's valuation was not arbitrary, oppressive, fraudulent, discriminatory, or manifestly excessive, and substantial evidence supported the district court's decision upholding it.
3. The Kimbroughs were not entitled to attorney fees under Idaho Code section 12-117(1) because that provision does not authorize an award of fees in an appeal from an administrative decision.

Questions Presented

1. Whether Idaho Code section 63-604 requires the agricultural-land exemption to apply to a homesite contiguous with land actively devoted to agriculture.
2. Whether the County's valuation of the Kimbroughs' homesite was arbitrary, oppressive, fraudulent, discriminatory, or manifestly excessive.
3. Whether the Kimbroughs were entitled to attorney fees under Idaho Code section 12-117(1).

Disposition

affirmed