Walter & Blossom Schnable Family Limited Partnership v. DOR

OCR transcription for search; preserved printed pages are authoritative

BEFORE THE MONTANA TAX APPEAL BOARD FILED

SEP 18 2024
Montana Tax Appeal Board
WALTER E. & BLOSSOM G.
SCHNABEL FAMILY LIMITED CASE Ne: PT-2024-19
PARTNERSHIP, LTD.,
Appellant,
FINDINGS OF FACT,
ee CONCLUSIONS OF LAW, ORDER,
AND OPPORTUNITY FOR
STATE OF MONTANA, JUDICIAL REVIEW
DEPARTMENT OF REVENUE,
Respondent.

STATEMENT OF THE CASE

This is an appeal of a final decision by the Granite County Tax Appeal Board
(CTAB) denying the Walter E. & Blossom G. Schnabel Family Limited Partnership,
LTD. (Taxpayer) a reduction in value on the subject land located at 62 North Sun Bear
Drive in Philipsburg, Montana (Subject Property). The DOR valued the 15.772 acre
Subject Property at $284,499 and the Taxpayer appealed the valuation to the CTAB
requesting a value of $134,003. CTAB heard the case on January 10, 2024, and
declined to reduce the value of the land. The Taxpayer appealed to MTAB on
February 12, 2024, per Mont. Code Ann § 15-2-301, requesting a land value of
$134,003. The MTAB hearing was conducted in Helena on Thursday, June 20, 2024,

and we affirm CTAB’s determination.

ISSUE TO BE DECIDED

Whether CTAB erred in maintaining the DOR-assessed value of the subject
land.

EXHIBIT LIST
The following evidence was submitted at the hearing:
Taxpayer Exhibits:
1. 2020 Land Class Codes.

. BEFORE THE MONTANA TAX APPEAL BOARD
WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF
MONTANA, DEPARTMENT OF REVENUE

DOR Exhibits:
A. Property Record Card;
B. Aerial Map;
Subdivision Map with Adjusted Comparable Sales;
Whiskey Flats Neighborhood Map;
Realty Transfer Certificate;
Residential Sales Verification form;
Land Model Spreadsheet;
Land Sale Packet Cover Letter;
Land Sale Packet;
Land Calculation for Subject Property; and

Ase rommoo

Photos of Subject Property.

PROCEDURAL HISTORY

The DOR valued the Subject Property at $284,499 for the 2023/2024 appraisal
cycle and notified the Taxpayers of that value by mailing them a Notice of
Assessment, dated June 30, 2023. Ex. A; MTAB Dkt. 3. The Taxpayer appealed the
DOR’s valuation to the CTAB on August 2, 2023, requesting a land value of
$134,003. MTAB Dkt. 3. The CTAB hearing was held on January 10, 2024, and the
CTAB’s decision denying the Taxpayer’s application for reduction was dated the
same day. Jd. The Taxpayer appealed to MTAB on February 12, 2024, per Mont.
Code Ann § 15-2-301, requesting a land value of $134,003. MTAB Dkt. 1. The MTAB
hearing was conducted in Helena on Thursday June 20, 2024, at which the following
were present:

a. Gary L. Snyder, General Partner and Taxpayer Representative; Shari L.
Snyder, General Partner; and

b. Kate Talley, DOR Counsel; Cindy McGinnis, Paralegal; Tedd Weldon,
Area Four Manager; Julie Goebel, Appraiser; and Timothy Skop,
Modeler.

The record includes all materials submitted to CTAB, a recording of the CTAB
hearing, all materials submitted to MTAB with the appeal, additional exhibits

BEFORE THE MONTANA TAX APPEAL BOARD
WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF
MONTANA, DEPARTMENT OF REVENUE

submitted by the parties prior to and at the MTAB hearing, and a transcript of the
MTAB hearing.

FINDINGS OF FACT
1. To whatever extent the following findings of fact may be construed as

conclusions of law, they are incorporated accordingly.

2. The Subject Property contains 15.772 acres and is owned by the Walter E. &
Blossom G. Schnabel Family Limited Partnership, LTD. Ex. A. The Subject
Property is located at 62 Sun Bear Drive in Philipsburg, Montana and is also
identified by its geocode 46-1573-24-2-02-23-0000. Id.

3. Taxpayer purchased the property in 2021, and DOR then reclassified it as tract
land and valued it at $134,003 for 2022. At the MTAB hearing, Gary Snyder,
the Taxpayer’s Representative (Taxpayer Representative) requested that the
Subject Property be valued at $134,003 based on the value established by the
DOR in the previous appraisal cycle of 2021/2022. MTAB HAr’g Tr. 3:1-9. The
DOR requested a value of $284,499 for the Subject Property for the 2023/2024
tax years. Id.

4. Prior to purchase in June of 2021, the Subject Property was contiguous with
other agricultural land in common ownership and met the statutory

requirements to be classified as non-qualified agricultural land. MTAB Hr’g Tr.
35:10-21.

5. DOR Appraiser, Julie Goebel, stated that before the Taxpayer purchased the
land, it was classified as non-qualified agricultural land because the land was
owned by the subdivision as one parcel, and the parcel was over 20 contiguous
acres. Ex. E; MTAB Hr’g Tr. 25:1-4. Ms. Goebel further defined non-qualified

agricultural land for the purpose of classification as any land between 20 and

LS)

BEFORE THE MONTANA TAX APPEAL BOARD |
WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF
MONTANA, DEPARTMENT OF REVENUE

160 acres in size and defined tract land as land under 20 acres in size. MTAB

HAr’g Tr. 22:16-18, 24: 11-12.

6. Ms. Goebel testified that non-qualified agricultural land is valued using the
average productivity of grazing land, whereas tract land is valued using
comparable sales of vacant land. MTAB Hr’g Tr. 25:5-10. Furthermore, unlike
non-qualified agricultural land, class four residential tract land is valued at full

market value. MTAB Hr’g Tr. 44: 1-3.

7. Before being purchased by the Taxpayer, the Subject Property was valued at
$873 in 2021 as it was classified as non-qualified agricultural land. Ex. A;
MTAB Hr’g Tr. 24:15-25:4. Taxpayer Representative testified that the Subject
Property was purchased in 2021 for the asking price of $260,000. MTAB Hr’g
Tr. 36:10-12, MTAB Dkt. 6. In 2022, the Subject Property’s value was raised to
$134,003 to reflect the land being reclassified from non-qualified agricultural
land to residential tract land because the parcel was less than 20 acres. Jd. In
2023, the assessed value was raised to $284,499 to reflect market appreciation

from the previous valuation cycle. Jd.

8. Ms. Goebel testified that she visited the Subject Property on June 4, 2024, to

assess the property characteristics and take photos of the property. Ex. K;
MTAB Hr’g Tr. 31:20-34:1.

9. The DOR received both a Realty Transfer Certificate (RTC) and a Residential
Sales Verification Form (RSV) generated by the sale of the Subject Property
and validated the sale as an arm’s length transaction. Ex. E, F; MTAB Hr’g Tr.
50:6-20. DOR Modeler, Tim Skop, testified that when reviewing RTCs and
RSVs to determine whether the transfer was a valid arm’s length transaction,
the DOR checks for whether any special considerations or extenuating

circumstances occurred during the transfer. Jd.

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

MONTANA, DEPARTMENT OF REVENUE

10. Asa valid arm’s length transaction, the Subject Property’s sale was used in the

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DOR’s neighborhood land valuation model. Ex. G; MTAB Ar’g Tr. 52:12-
53:24. The model uses the DOR’s common statewide lien date of January 1,
2022, to determine market values for the 2023/2024 appraisal cycle. Ex. G;
MTAB Ar’g Tr. 51:6-18.

Ms. Goebel testified that once the Subject Property was purchased by
Taxpayer, it was no longer part of the larger contiguous parcel and did not meet
the acreage requirement for non-qualified agricultural land. MTAB Hr’g Tr.
41:1-6, 47:22-48:15. As a parcel less than 20 acres in total size, the 15.772
acres of the Subject Property were no longer presumed to be agricultural and
the parcel was required to be reclassified as class four residential tract land by

statute. Id.

The DOR is required to value land according to its present use as of the
2023/2024 lien date. MTAB Hr’g Tr. 44: 1-19. At the time of the lien date, the
Subject Property was owned by the Taxpayer and did not automatically qualify
for agricultural classification due to no longer being above 20 acres in total
size. MTAB Hr’g Tr. 37: 18-38:8. Ms. Goebel stated that the DOR could
reconsider whether the Subject Property met the agricultural classification
requirements if Taxpayer submitted an agricultural land classification

application, but the Taxpayer had not done so. Id.

DOR Area Manager, Tedd Weldon, testified that the DOR is required by law to
implement a “...general and uniform method of classifying lands in the state
for the purpose of securing equitable and uniform basis of assessment of land
for taxation purposes.” MTAB Hr’g Tr. 21: 1-6. Mr. Weldon clarified that this
provision does not require the DOR to ensure that land in one county is valued
the same as land in another county, only that the methods used to value the land

are the same. Jd.

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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MONTANA, DEPARTMENT OF REVENUE

Mr. Skop testified that the DOR determines the market value of land by using
neighborhood land models that derive values in part from multiple regression
analysis of various validated land sales in a particular geographic area called a
neighborhood. Ex. J; MTAB Hr’g Tr. 12:23-13:22. The value established by a
neighborhood land model is contingent on sales prices of land, adjusted by the
model from date of sale to the common lien date of January 1, 2022, and for
location, among other factors. Jd. The Granite County rural land model for
neighborhood 246.001 was used to determine market value of the Subject
Property. Ex. G; MTAB Hr’g Tr. 53:11-54:4. Sales contained in that model are
from the same general rural Granite County area and the model does not
contain sales from the towns of Philipsburg or Drummond. /d. The sales
contained in the land model have the same physical, environmental,

governmental, and social characteristics affecting the properties. Id.

The land model used to value the Subject Property contained 75 properties that
sold between 2018 and 2022, 27 of which were located in the Subject
Property’s Whiskey Flats subdivision. Ex. G; MTAB HAr’g Tr. 52:12-53:24,
58:1-5.

The Granite County rural model documented an eight percent higher sale price
per acre in the Whiskey Flats subdivision as determined by the 27 sales in that
subdivision. MTAB Hr’g Tr. 57:23-58:18. Mr. Skop testified that “...in the
case of Whiskey Flats, based on 27 sales in that subdivision, we found that they
were selling about eight percent higher, so instead of $47,000 we were looking
at more closer to $51,000 for the base acre in Whiskey Flats.” Jd. The eight
percent influence is called a positive influence and was applied to the base rate
of 47,000. MTAB Hr’g Tr. 13:9-22, 15:21-23. The resulting $50,760 was then
multiplied by the land size minus the one base acre and that product was then
raised to the power of the incremental rate, which was 27.6249. Id. The
calculation yielded a predicted market value for the Subject Property’s land of
$284,499 as of January 1, 2022, for the 2023/2024 tax cycle. Id.

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BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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MONTANA, DEPARTMENT OF REVENUE

The land model used to value the Subject Property had a statistical R-squared
rating of around 83, which, according to Mr. Skop is “pretty good for rural
areas where there’s a lot of differentiation in the data.” Ex. G; MTAB Hr’g Tr.
56:22-57:19. The R-square value is an indication of how well a model is

describing data, and an R-square value above 70 denotes an accurate model. Jd.

Mr. Weldon stated that the first property to sell in the Whiskey Flats
subdivision sold in 2018 for $60,000. MTAB Hr’g Tr. 15:9-17. Comparatively,
the Subject Property sold in 2021 for $260,000.

Mr. Weldon testified that the median residential value increase for Granite
County from January 1, 2020, to January 1, 2022, was 67 percent. MTAB Hr’g
Tr. 19:11-15.

The Taxpayer Representative made the argument that by the DOR not
comparing the purchase of his land in other Montana counties, the DOR was in
violation of the Montana Constitution Article VIII Property Tax
Administration, Sections 3 and 4 by failing to equalize his purchase with other
purchases in Montana. MTAB Hr’g Tr. 19:11-25, 20:1-19, 69:2-9. He argued

that DOR should be comparing sales in Granite County to sales in rural eastern

Montana. Jd.

The Taxpayer Representative raised questions about the calculation of mills,
specifically, who is in charge of determining the mills, how are the mills

calculated, and why the mills raised his property tax. MTAB Hr’g Tr. 8:5-17.

JURISDICTION AND STANDARD OF REVIEW
The Montana Tax Appeal Board is an independent agency not affiliated with
the Montana Department of Revenue. Mont. Const., Art. VIII § 7; Mont. Code
Ann. § 15-2-101. The Taxpayer filed a timely appeal of the DOR’s decision to

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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the MTAB. Therefore, this Board maintains jurisdiction to hear and decide this
matter. Mont. Code Ann. § 15-2-301.

This Board may hear appeals de novo. Dept. of Revenue v. Burlington N., 169
Mont. 202, 213-14, 545 P.2d 1083 (1976). “A trial de novo means trying the
matter anew, the same as if it had not been heard before and as if no decision
had been previously rendered.” McDunn v. Arnold, 2013 MT 138, § 22, 370
Mont. 270, 275, 303 P.3d 1279, 1282.

The Board’s order is final and binding upon all parties unless changed by

judicial review. Mont. Code Ann. § 15-2-301(6).

CONCLUSIONS OF LAW
To whatever extent the following conclusions of law may be construed as

findings of fact, they are incorporated accordingly.

“All taxable property must be appraised at 100% of its market value....” Mont.
Code Ann. § 15-8-111.

“[I]n connection with any appeal under [Mont. Code Ann. § 15-2-301], the
Montana board is not bound by common law and statutory rules of evidence or
rules of discovery and may affirm, reverse, or modify any decision. To the
extent that this section is in conflict with the Montana Administrative
Procedure Act, this section supersedes that act.” Mont. Code Ann. $ 15-2-
301(5).

DOR is entitled to a “presumption of correctness if its decisions are pursuant to
an administrative rule or regulation, and the rule or regulation is not arbitrary,
capricious or otherwise unlawful.” Burlington N., 169 Mont. at 214, 545 P.2d

at 1090. However, DOR cannot rely entirely on the presumption in its favor

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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and must present a modicum of evidence showing the propriety of their action.

Western Air Lines v. Michunovich, 149 Mont. 347, 353, 428 P.2d 3, 7 (1967).

The Taxpayer bears the burden of proving the error of DOR’s decision.
Farmers Union Cent. Exch. v. Dep’t of Revenue, 272 Mont. 471, 476, 901 P.2d
561, 564 (1995); Western Air Lines, 149 Mont. at 353, 428 P.2d at 7. '

“* Assessment formulations’ by [the Montana Tax Appeal Board] should be
upheld unless there is a clear showing of an abuse of discretion.” Peretti v.
Dep’t of Revenue, 2016 MT 105, { 15, 383 Mont. 340, 344, 372 P.3d 447, 450
(citing O’Neill v. Dep’t of Revenue, 2002 MT 130, § 23, 310 Mont. 148, 155,
49 P.3d 43, 47); see Northwest Land & Dev. v. State Tax Appeal Bd., 203
Mont. 313, 317, 661 P.2d 44, 47 (1983) (overruled on other grounds by DeVoe
v. Dep’t of Revenue, 263 Mont. 100, 866 P.2d 228 (1993)).

When construing a statute, it is the Board’s role to “determine what in terms or
substance is contained in it, and not to insert what has been omitted or to omit
what has been inserted.” State v. Minett, 2014 MT 225, § 12, 376 Mont. 260,
263, 332 P.3d 235, 238; Mont. Code Ann. § 1-2-101.

In the construction of a statute, the intention of the legislature is to be pursued
if possible. When a general and particular provision are inconsistent, the latter
is paramount to the former, so a particular intent will control a general one that

is inconsistent with it.” Mont. Code Ann. § 1-2-102.

“When faced with a problem of statutory construction great deference must be
shown to the interpretation given the statute by the officers or agency charged

with its administration.” Dep ’t of Revenue v. Puget Sound Power & Light Co.,
179 Mont. 255, 262, 587 P.2d 1282, 1286 (1978) (citing Udall v. Tallman, 380
U.S. 1, 16 (1965)).

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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“[T]ax statutes are to be strictly construed against the taxing authority and in
favor of the taxpayer.” Western Energy Co. v. Dep’t of Revenue, 1999 MT 289,
4 10, 297 Mont. 55, 58, 990 P.2d 767, 769.

“Administrative agencies enjoy only those powers specifically conferred upon
them by the legislature. Administrative rules must be strictly confined within
the applicable legislative guidelines. Indeed, it is axiomatic in Montana law
that a statute cannot be changed by administrative regulation. We look to the
statutes to determine whether there is a legislative grant of authority.” Bick v.

State Dep’t of Justice, Div. of Motor Vehicles, 224 Mont. 455, 457, 730 P.2d
418, 420 (1986).

“TA ]dministrative regulations interpreting the statute made by agencies charged
with the execution of the statute are entitled to respectful consideration.” Puget

Sound Power & Light Co., 179 Mont. 255, 266, 587 P.2d 1282, 1288 (1978).

The Board “may not amend or repeal any administrative rule of the
department,” but may enjoin its application if the Board concludes the rule is

“arbitrary, capricious, or otherwise unlawful.” Mont. Code Ann. § 15-2-301(5).

The Legislature intended the Department to utilize a number of different
approaches or combination of approaches, including the income approach,
sales comparison approach, and cost less depreciation approach, depending on
the market where the appraisals take place, when it assesses property and
estimates market value. Albright v. State, 281 Mont. 196, 208-09, 933 P.2d
815, 823 (1997).

“Parcels of land of 20 acres or more but less than 160 acres under one
ownership that are not eligible for valuation, assessment, and taxation as
agricultural land under 15-7-202(1), which are considered to be nonqualified

agricultural land. Nonqualified agricultural land may not be devoted to a

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BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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MONTANA, DEPARTMENT OF REVENUE

commercial or industrial purpose. Nonqualified agricultural land is valued at
the average productive capacity value of grazing land.” Mont. Code Ann. $ 15-
6-133(c).

“All lands must be classified according to their use or uses.” Mont. Code Ann.

§ 15-7-103(2).

“Market value is the value at which property would change hands between a
willing buyer and a willing seller, neither being under any compulsion to buy
or to sell and both having reasonable knowledge of relevant facts.” Mont. Code

Ann. § 15-8-111(2).

“Properties in 15-6-134, under class four, are assessed at 100% of market

value.” Mont. Code Ann. § 15-8-111(8)(d).

“The department shall administer and supervise a program for the reappraisal
of all taxable property within classes three and four. The department shall
adopt a reappraisal plan by rule. The reappraisal plan adopted must provide that
all class three and four property in each county is revalued by January 1 of the
second year of the reappraisal cycle, effective for January 1 of the following

year, and each succeeding two years...” Mont. Code Ann. § 15-7-111(5).

“Subject to the provisions of this section, a governmental entity that is
authorized to impose mills may impose a levy sufficient to generate the amount
of property taxes actually assessed in the prior year plus one-half of the average
rate of inflation for the prior 3 years. The maximum number of mills that a
governmental entity may impose is established by calculating the number of
mills required to generate the amount of property tax actually assessed in the

governmental unit in the prior year based on the current year taxable value, less

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BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. S TATE OF

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MONTANA, DEPARTMENT OF REVENUE

the current year’s newly taxable value, plus one-half of the average rate of

inflation for the prior 3 years.” Mont. Code Ann. § 15-10-420(1)(a).

DISCUSSION
The Taxpayer Representative made various arguments that the methods used
by the DOR were in violation of the Montana Constitution’s requirement that

assessment be equalized among taxpayers.

The Taxpayer Representative similarly argued that the methods used to set a
market value on his land were a sales tax, presumably because the comparable
sales method of valuation relies upon market sales to establish value. We were
not convinced that his use of the term “sales tax” accurately reflects the market
sales approach to finding value, and do not find this argument persuasive that

the DOR erred in appraising the land by relying on sales of nearby properties.

These arguments are not supported by Montana law and are irrelevant to the
jurisdiction and review of tax appeals. Tax appeal decisions in cases such as

this are limited to determining the correct market value.

Similarly, although the Taxpayer Representative raised the issue of mills
applied to tax for calculating the tax due, MTAB has no jurisdiction to set or
adjust mills, nor any jurisdiction to set or adjust tax rates. These policy

decisions are left to elected county officials and the Montana Legislature.

Regarding the Taxpayer Representative’s contention that sales in other parts of
Montana should have been compared to his sale, it would not be fair or
reasonable for the DOR to consider sales in the far reaches of eastern Montana
to establish the market value in Philipsburg. It is far more equitable that the
DOR evaluated the 27 sales in the Taxpayer’s own Granite County subdivision

to find market value, and we believe they did so correctly.

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BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF |

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In turn, there is no better evidence of market value for this Board to consider
than the actual sale price of the Subject Property. That price is in evidence and
uncontroverted. The value in dispute has been set higher than the sale price by
the DOR to account for the appreciation of value between the sale date of June
10, 2021, and the statewide lien date of January 1, 2022. We find that
appreciation over those six months to be realistic in an increasing regional real

estate market in a desirable location in Granite County, Montana.

We can reasonably conclude the market value of land in Philipsburg is
appreciating when we consider the testimony of Mr. Weldon that lots in this
subdivision were priced 5 years ago at as low as $60,000, but the Taxpayer
paid $260,000 in 2021. Using the market value standard established by the
Legislature, the present value determined by the DOR is higher than the value
determined when the subject was re-classified as tract land, but we believe the
new value correctly reflects that market value appreciation over the time

period.

The Taxpayer Representative cited no violations of Montana law by the DOR,
and even if he disagrees with the law as written, it is the Montana Legislature

which writes the law, not the DOR.

DOR witnesses explained the reason the appraised value increased, which was
that it had been properly re-classified from non-qualified agricultural land, and

upon sale was correctly re-classified for its use on the lien date as tract land.

The DOR credibly testified that once properly classified, the 2023/2024 land
model used to determine market value justified the positive influence in this
subdivision of 108% compared to other land in this Granite County rural

neighborhood. We find their method was properly executed and their value is

upheld.

BEFORE THE MONTANA TAX APPEAL BOARD

WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF

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MONTANA, DEPARTMENT OF REVENUE

The responses of the witnesses to Board questions and the cross-examination
posed by the Taxpayer Representative convinced this Board the DOR
employees understood and could explain the methods used and why they are
reliable predictors of market value within the confines of statutes,

administrative rule, and DOR policy under which the DOR does its work.

MTAB’s review is confined to whether the Taxpayer provided sufficient
evidence and testimony to convince this Board that the DOR erred in setting
the market value of the Subject Property. We find that Taxpayer Representative
did not provide sufficient evidence and testimony to prove any error by the

DOR in valuing his land for 2023/2024.

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BEFORE THE MONTANA TAX APPEAL BOARD
WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF
MONTANA, DEPARTMENT OF REVENUE

ORDER
57. The decision of the Granite County Tax Appeal Board is upheld, and the value
assigned to the subject land shall be maintained at $284,499 for 2023/2024.

Dated this 18" day of September 2024.

Toa Al. MBA.

David L. McAlpin, Chairman \

/} 2) {

Amie Zendron, Member

T pes, Brew "

Travis Brown, Member

Dim.

Notice: You are entitled to judicial review of this Order by filing a petition in district
court within 60 days of the service of this Order. The Department of Revenue shall
promptly notify this Board of any judicial review to facilitate the timely transmission

of the record to the reviewing court. Mont. Code Ann. $15-2-303(2).

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. BEFORE THE MONTANA TAX APPEAL BOARD
WALTER E. & BLOSSOM G. SCHNABEL FAMILY LIMITED PARTNERSHIP, LTD., v. STATE OF
MONTANA, DEPARTMENT OF REVENUE

Certificate of Service

I certify that I caused a true and correct copy of the foregoing Findings of Facts and
Conclusions of Law to be sent by email and United States Mail via Print & Mail

Services Bureau of the State of Montana on September 18, 2024, to:

Gary L. Snyder

Walter E. & Blossom G. Schnabel Family Limited Partnership, LTD.,
62 N Sun Bear Dr.

P.O. Box 1053

Philipsburg, MT 59858

Katherine Talley

State of Montana, Department of Revenue
Legal Services Office

P.O. Box 7701

Helena, MT 59604-7701

Paula Gilbert

State of Montana, Department of Revenue
Property Assessment Division

P.O. Box 8018

Helena, MT 59604-8018

Billie Ann Kulaski

Granite County Tax Appeal Board
P.O. Box 925

Philipsburg, MT 59858

le ee

Rina Sanderson, Legal Secretary

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