Manteno Community Unit School District No. 5 v. Illinois Property Tax Appeal Board

Illinois Appellate Court
Civil Court
Property Tax
Citation
Case Number: 
2020 IL App (3d) 180384
Decision Date: 
Monday, August 17, 2020
District: 
3d Dist.
Division/County: 
PTAB
Holding: 
Reversed.
Justice: 
WRIGHT

(Modified upon denial of rehearing 9/22/20.) Plaintiff appealed county board of review’s 2013 property tax assessment of its supportive living facility that houses Medicaid-eligible and private-pay residents to Illinois Property Tax Appeal Board (PTAB). School District intervened in PTAB proceeding. After hearing, PTAB reduced facility’s 2013 property tax assessment. PTAB’s decision was based on an improper method for applying the income capitalization approach required by section 10-390 of Property Tax Code. Facility’s fair cash value should have been based amount no less than income earning capacity attributable to the 50-55% Medicaid-eligible resident, and on the added true capacity to earn real estate income from the remaining percentage of higher income residents.(LYTTON and CARTER, concurring.)