1411 North State Condominium v. The Illinois Property Tax Appeal Board

Illinois Appellate Court
Civil Court
Property Tax
Citation
Case Number: 
2016 IL App (1st) 143757
Decision Date: 
Thursday, December 29, 2016
District: 
1st Dist.
Division/County: 
Property Tax Appeal Board
Holding: 
Reversed and remanded with directions.
Justice: 
MIKVA

Direct appeal from final decision of Property Tax Appeal Board ordering no change to 2009 taxes assessed by assessor and certified by Board of Review for 14-unit condominium property. Condo association's appraiser died before hearing was held. Appeal Board ruled that death of appraiser rendered appraisal inadmissible, and thus Association lacked any admissible evidence to support its valuation of property, and Board sustained assessment certified by Board of Review. Manner and timing of Appeal Board's decision to reverse hearing officer's evidentiary ruling that appraisal would be considered and given appropriate weight, after hearing was concluded, and giving Association no opportunity to present other evidence, resulted in unfair and inequitable hearing. On remand, proofs should be reopened to permit Association to obtain and submit new appraisal or other evidence to establish value of property, and new hearing should be held. (CONNORS and HARRIS, concurring.)