State Board of Tax Commissioners v. Town of St. John

702 N.E.2d 1034 (1998)

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State Board of Tax Commissioners v. Town of St. John

Indiana Supreme Court
702 N.E.2d 1034 (1998)

Facts

Under the property-taxation clause of the Indiana Constitution, the Indiana legislature (the legislature) was responsible for providing a uniform and equal rate of property taxation. The property-taxation clause also required the legislature to promulgate regulations to secure a just valuation for taxation of property. The legislature created the State Board of Tax Commissioners (the board) (defendant) and delegated to the board the responsibility for establishing rules to assess property according to its true tax value. The definition of true tax value was based on statutory factors and any other factor that the board determined by rule was just and proper. One statutory factor was the cost of improvements, which was determined by the board’s cost schedules. Moreover, Indiana Code § 6-1.1-31-6(c) stated that true tax value did not mean fair market value. The town of St. John (plaintiff) brought suit, contending that § 6-1.1-31-6(c) and the cost schedules were unconstitutional. The tax court held that § 6-1.1-31-6(c) violated the property-taxation clause. Further, the tax court found that the cost schedules contained arbitrary figures and formulas that had little or no reference to actual value or worth. The tax court thus held that the cost schedules violated the property-taxation clause. The board appealed.

Rule of Law

Issue

Holding and Reasoning (Dickson, J.)

Concurrence/Dissent (Sullivan, J.)

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