Petition for Review of order of the Illinois Property Tax Appeal Board. Nos. 96--1638--C--2 97--1466--C--3
The opinion of the court was delivered by: Justice McLAREN
Petitioner, the Winnebago County Board of Review (Board of Review or Board), appeals an order of respondent State of Illinois Property Tax Appeal Board (PTAB) reducing two tax assessments the Board had placed on property owned by respondent Alpine Bank of Illinois, Inc. (Alpine Bank). The Board appeals (see 35 ILCS 200/16--195 (West 1998)), asserting that the PTAB's order is against the manifest weight of the evidence. We affirm. The Alpine Bank property consists of 102,473 square feet of land improved with a three-story building. Each floor is about 15,420 square feet, making about 46,260 square feet of above-grade gross floor area. The first floor has been occupied since August 26, 1996. The other two floors are essentially unfinished and would have to be "built out" before they could be occupied.
The Board of Review gave the property a prorated assessment of $651,367 for 1996 and an assessment of $1,184,292 for 1997. The Board listed the property's market value for 1996 at $4,467,415. According to the PTAB's order, the Board's 1997 assessment implies a market value of $3,561,780 under the applicable assessment rate. (This finding is not in dispute on appeal.) Alpine Bank filed appeals with the PTAB, asserting that the Board of Review had overvalued the property for 1996 (case No. 96--1638--C--2) and 1997 (case No. 97--1466--C--3). The Rock River Water Reclamation District and Community College District No. 511 intervened, but neither submitted evidence and the PTAB found them in default.
Alpine Bank and the Board of Review each submitted a report of an expert appraiser who also testified at the hearing. Alpine Bank's expert, John Hill, estimated the value of the property as of August 26, 1996, while the Board's expert, Charles Davidson, used January 1, 1997, as the valuation date. However, the parties stipulated that, between those dates, there was no improvement to or additional occupancy of the building. Thus, the parties agree that the proper valuation is the same for either date.
Each appraiser estimated the property's market value according to the cost, sales comparison, and income approaches. The PTAB relied primarily on the sales comparison method in reaching its decision and that choice of methodology is not at issue on appeal. Therefore, we summarize the evidence only as it relates to the sales comparison method of valuation and to how the PTAB adjusted the valuation of the property to account for the cost of building out the second and third floors.
The Davidson report states that applying the sales comparison method gives the property a market value of approximately $3,430,000. Davidson used nine comparable sales, the data for which we summarize as follows:
No. Sale Price Price/Square Foot