Background
Claudette L. Wilson, as trustee, owns a single-family residence on 10.2 acres in Wilmington. After a 2024 statistical reappraisal, the Town valued the property at $685,360. The Board of Civil Authority upheld that valuation, and Wilson appealed to the Director of Property Valuation and Review.
At a de novo hearing, Wilson’s appraiser supported a fair market value of $665,000 and proposed an equalization ratio of 0.70 based on 135 town sales occurring between April 2024 and June 2025. The Town’s assessor presented a comparative-sales analysis supporting a value of $676,100. The hearing officer credited Wilson’s appraisal and set fair market value at $665,000, but rejected her proposed equalization ratio because the sales period could bias the calculation and she had not supplied records substantiating the underlying sales and listed values. The officer instead applied Wilmington’s state-calculated common level of appraisal of 0.9138, producing an equalized listed value of $607,700.
The Court’s Holding
The Vermont Supreme Court affirmed. It held that Wilson was not entitled to a remand to submit additional sales evidence because she had a full opportunity to present evidence at the de novo PVR hearing and offered no good reason for failing to present the additional material then. Judicial review was confined to the agency record, and the hearing notice had warned the parties that they needed to present their evidence at the hearing.
The Court further held that the hearing officer acted within her discretion by rejecting Wilson’s unsupported equalization ratio and applying the town-wide common level of appraisal. The officer explained the deficiencies in Wilson’s methodology, and the resulting decision was rationally supported by the record. The hearing officer also had no independent obligation to develop or produce the “best data available”; the parties bore responsibility for supporting their positions.
Key Takeaways
- A taxpayer seeking a property-tax adjustment must establish both fair market value and a reliable equalization ratio.
- A town-wide common level of appraisal may be used when the taxpayer’s proposed alternative ratio is not adequately supported.
- A party seeking to add evidence during judicial review must show good reasons for not presenting it in the administrative proceeding.
Why It Matters
The decision underscores that taxpayers must present complete, verifiable equalization evidence at the PVR hearing rather than expect an opportunity to supplement the record on appeal. Even when a taxpayer successfully challenges the Town’s fair-market-value evidence, an inadequately supported alternative equalization ratio can leave the state-calculated town-wide ratio controlling.