Evan F. Danno Revocable Living Trust

PT-2026-16Monttc

Texte intégral

BEFORE THE MONTANA TAX APPEAL BOARD
EVAN F. DANNO REVOCABLE
LIVING TRUST,
Appellant,
V.
STATE OF MONTANA,
DEPARTMENT OF REVENUE,
Respondent.
CASE :PT-2026-16
FINDINGS OF FACT,
CONCLUSIONS OF LAW, ORDER,
AND OPPORTUNITY FOR
JUDICIAL REVIEW
SEP 2 5 2026
Montana Tax Appeal Board
STATEMENT OF THE CASE
This is an appeal of a final decision by the Flathead County Tax Appeal Board
(CTAB) denying Evan F. Danno Revocable Living Trust (Taxpayer) a reduction in the
assessed value of the subject property located at 522 High Country Drive, Kalispell,
Montana (Subject Property). The Taxpayer appealed that outcome to the Montana Tax
Appeal Board (MTAB) on March 9,2026. The Board modifies the CTAB's determination.
ISSUE TO BE DECIDED
Whether the CTAB erred in affirming the Department's valuation of the Subject
Property.
EXHIBIT LIST
The following evidence was submitted at the hearing:
Taxpayer Exhibits:
1. Title of Mobile Home;
2. Mont. Code Ann. § 15-1-101 and §15-8-111;
3. Exterior Photos of Mobile Home;
4. Interior Photos of Mobile Home;
5. Tax Assessments 2013, 2014, 2016, 2018,2020, 2022,2024-2026;
6. Mont. Code Ann. § 15-6-241;
1
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
7. Department's Mobile Home Detailed Page;and
8. Comparable Mobile Home Advertisements and Sales Documents.
Department Exhibits:
A. Original Property Record Card and 2025 Classification and Appraisal
Notice;
B. AB-26 Determination Letter, December 11, 2025, Revised Assessment
Notice and Updated Property Record Card;
C. Updated Property Record Card;
D. Mont. Code Ann. § 15-6-241; and
E. Comparable Examples.
PROCEDURAL HISTORY
The Department of Revenue (Department) initially valued the Subject Property at
$14,330 for the 2025-2026 appraisal cycle. Ex. A; MTAB Dkt. 3; MTAB Hr'g Tr. 4:1-2.
The Taxpayer filed an AB-26 Request for Informal Classification and Appraisal Review
with the Department, and the Department issued a Form AB-26 Determination Letter on
December 11, 2025, reducing the value to $12,810. Ex. B. The Taxpayer appealed the
Department's valuation to CTAB on December 26;2025.MTABDkt. 3. The CTAB hearing
was held on February 23, 2026, and the CTAB's decision denying the Taxpayer's
application for reduction was sent to the parties on February 23, 2026. Id. After the CTAB
hearing, the Department made further adjustments, reducing the value first to $9,890 and
ultimately proposing a value of $9,420 at the MTAB hearing. MTAB Hr'g Tr. 1:2-6. The
Taxpayer appealed to MTAB on March 9, 2026, per Mont. Code Ann. § 15-2-301,
requesting a total value of $0. MTAB Dkt. 1. The MTAB hearing was conducted in Helena
on June 30, 2026, at which the following were present:
a. Evan F. Danno, Taxpayer (via Zoom); and
b. Kristina K. Warren, Department Counsel; Andrew Pritchard, Area Manager
(via Zoom); and Timi Severson, Appraiser (via Zoom).
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
The record includes all materials submitted to CTAB, a recording of the CTAB
hearing, all materials submitted to MTAB with the appeal, additional exhibits 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 is a 1965 Guerdon Great Lakes single-wide mobile home
owned by the Evan F. Danno Revocable Living Trust. Ex. 1, A. The mobile home
measures 10 feet by 46 feet and has one bedroom and one bathroom. Ex. A. The
Subject Property is identified by geocode 07-3967-01-1-02-30-8001 and is
located at 522 High Country Drive, Kalispell, Montana. Ex. A.
3. The Department initially valued the Subject Property at $ 14,330 for the 2025-
2026 appraisal cycle. Ex. A. Following the Taxpayer's AB-26 review, the
Department removed the pole building from the mobile home property record (M-
PRC)1 and reduced the value to $12,810. Ex. B; MTABHr'g Tr. 22:18-23:5. The
CTAB denied the Taxpayer's appeal and affirmed the Department's $12,810
value. MTAB Dkt. 3. The Taxpayer appealed to MTAB on March 9, 2026,
requesting a value of $0. MTAB Dkt. 1. At the MTAB hearing, the Department
proposed a total value of $9,420 aflter removing a prefabricated wood stove
located in the enclosed porch from the M-PRC. MTAB Hr 'g Tr. 2:2-7, 43:4-13.
1 For clarity, the Board uses the abbreviation "M-PRC" when referring to the mobile home property
record card to distinguish from the property record card of the underlying land.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
4. Mr. Danno argued that under Mont. Code Ann. § 15-1-101, the Subject Property
is personal property because it is not situated on a foundation and retains its axle
and wheels. MTAB Hr 'g Tr. 5:13-15.
5. Mr. Danno testified that the mobile home has been situated beneath a pole barn
since 1982. MTAB Hr'g Tr. 5:21-24. Mr. Danno testified that the mobile home is
not affixed to the pole barn, apart from limited wood framing associated with the
steps. MTAB Hr 'g Tr. 14:1-5.
6. Mr. Danno testified that the pole barn is real property and would not transfer with
a sale of the mobile home. MTAB Hr 'g Tr. 5:3-6. Department Appraiser Timi
Severson testified that the Department separately coded the pole barn and removed
it from the M-PRC and added it to the real property record card. MTAB Hr 'g Tr.
22:18-23:5.
7. Mr. Danno testified that the mobile home was purchased in 1982 for $2,500.
MTAB Hr 'g Tr. 5:21-25. Mr. Danno further testified that a tenant has occupied the
mobile home since 1996 and paid monthly rent of $325 until Mr. Danno increased
the rent to $525 in 2025. MTAB Hr 'g Tr. 5:24-6:2. Mr. Danno attributed the rent
increase to higher property taxes, which he testified caused him to lose money on
the property. Id. Mr. Danno testified that he carries liability insurance but does not
insure the mobile home for its value. MTAB Hr 'g Tr. 12:11-12. Mr. Danno stated
that the tenant only uses the kitchen, bathroom, and living room, as the bedroom is
locked of f.MTAB Hr'gTr. 6:10-18, 12:19-21.
8. Mr. Danno contended that mobile homes only depreciate in value and that, if the
mobile home were removed, the land would return to non-qualified agricultural
classification and lose the base one-acre residential value. MTAB Hr'g Tr. 6:16-
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
24, ll.-19-24.Mr. Danno submitted online advertisements for older mobile homes
located in Montana, Idaho, and Washington which are being offered for amounts
ranging from free to $5,000. Ex. 8; MTAB Hr'g Tr. 9:12-10:25. The
advertisements reflect asking prices rather than verified market sales. Ex. 8; MTAB
Hr'gTr. 13:15-19.
9. Mr. Danno testified that the bathroom is connected to a septic system. MTAB Hr 'g
Tr. 12:15-21. Mr. Danno testified that the leaking roof is covered with plastic
secured by wood framing. MTAB Hr 'g Tr. 13:1-14. Mr. Danno testified that the
pole barn protects the mobile home from the weather and that the roof would not
withstand exposure without that protection. MTAB Hr 'g Tr. 13:1-14. Mr. Danno
further testified that some windows are boarded, the trailer tires are unusable, the
interior is damaged, and insulation is fastened to the interior walls. Ex. 3, 4; MTAB
Hr'gTr. 14:22-25, 17:11-24.
10. Mr. Danno testified that a purchaser could not retain the mobile home at its current
location and would have to move it within 30 days. MTAB Hr 'g Tr. 6:22-24. Mr.
Danno estimated that removing the mobile home would cost at least $2,000.
MTABHr'gTr. 6:15-16, 56:6-9.
11. Ms. Severson agreed that a potential purchaser would want to know whether the
mobile home had to be moved upon sale. MTAB Hr 'g Tr. 27:20-28:1. Ms.
Severson testified, that the Department did not calculate or apply a removal-cost
adjustment when valuing the Subject Property. MTAB Hr 'g Tr. 28:6-13.
Department Area Manager Andrew Pritchard testified that, when verifying mobile
home sales through area dealers, the Department attempts to identify moving and
setup costs included in a reported purchase price. MTAB Hr 'g Tr. 51:9-19. Mr.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
Pritchard testified that the Department excludes those costs to determine the
amount paid for the mobile home itself. Id.
12. Ms. Severson testified that the Department's original $14,330 valuation included
the mobile home and associated improvements. Ex. A; MTAB Hr'g Tr. 18:14-24.
Ms. Severson further testified that the amount consisted of $12,810 attributed to
the M-PRC and $1,520 attributed to the pole building. Ex. A; MTAB Hr 'g Tr.
22/22-23/5. The Department's Classification and Appraisal Notice identified
market appreciation as the reason for the increase. Ex. A.
13. Mr. Pritchard testified that, after the CTAB hearing, the Department removed the
enclosed porch from the M-PRC and reduced the value to $9,890. Ex. C; MTAB
Hr 'g Tr. 43:4-10. Mr. Pritchard testified that the enclosed porch was removed
because it benefited the landowner and was attributable to the real property. MTAB
Hr'g Tr. 42:8-17. Before the MTAB hearing, Mr. Pritchard also removed a
prefabricated wood stove located in the enclosed porch, reducing the Department's
proposed value from $9,890 to $9,420. MTABHr'g Tr. 43:5-13.
14. Ms. Severson testified that the Department valued the Subject Property using the
cost approach. MTAB Hr'g Tr. 18:23-24. Ms. Severson testified that the
Department used Marshall & Swift, RSMeans, and localized cost data to estimate
the replacement-cost-new value of the Subject Property and then deducted
depreciation. MTAB Hr 'g Tr. 19:7-11.
15. The Department assigned the Subject Property a 17-percent-good factor and a low
overall grade, with fair ratings for condition, utility, and property desirability, and
an average rating for location desirability. Ex. C; MTABHr'g Tr. 36:2-16, 54:4-
23.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
16. Ms. Severson retained the 1985 effective year that had been assigned to the
Subject Property by the previous appraiser. MTAB Hr'g Tr. 32:9-18. Ms.
Severson testified that she did not know what improvements or updates originally
supported the 1985 effective year. Id. Ms. Severson retained the effective year
because she believed it adequately recognized the Subject Property's obsolescence
and depreciation. MTABHr'g Tr. 32:17-33:6.
17. Mr. Pritchard testified that the Department's mobile home cost tables reach their
maximum age-based depreciation after approximately 35 to 40 years. MTABHr'g
Tr. 42:18-43:10; 52:1-10. Mr. Pritchard testified that substituting the mobile
home's actual 1965 construction year for the 1985 effective year would not reduce
the 17-percent-good factor or resulting value. Id. Mr. Pritchard testified that the
Subject Property's depreciation had "bottomed out." Id.
18. Ms. Severson attempted to arrange an interior inspection and met the tenant at the
property on December 2, 2025. MTAB Hr'g Tr. 21:24-22:17. Ms. Severson did
not enter the mobile home because Mr. Danno was not present to authorize entry.
Id. Neither Ms. Severson nor Mr. Pritchard inspected the mobile home's interior in
person. MTAB Hr'g Tr. 23:16-18, 40:7-8. Ms. Severson did not inspect the roof
or tires. MTAB Hr 'g Tr. 26:16-21. Ms. Severson reviewed the Taxpayer's interior
photographs and testified that they did not change her opinion of the Subject
Property's value. MTAB Hr 'g Tr. 23:6-12. Mr. Pritchard testified that the
photographs were too dark to clearly establish the interior condition. MTAB Hr 'g
Tr. 47:13-19.
19. Ms. Severson testified that the low grade, fair condition, desirability, and utility
ratings, 1985 effective year, and existing depreciation are already accounting for
substantial obsolescence and deferred maintenance. MTAB Hr'g Tr. 23:6-12,
35:7-11.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
20. The Department also considered using the sales comparison approach to value the
Subject Property but determined the cost approach to be the more appropriate
valuation method. MTAB Hr'g Tr. 19:1-6. Mr. Pritchard testified that the sales
comparison approach estimated the Subject Property's value to be approximately
$23,000. MTAB Hr'g Tr. 41:8-13, 53:12-21. The Department selected the lower
cost approach value because the adjustments required under the sales comparison
approach exceeded the Department's preferred parameters. Id.
21. Mr. Pritchard testified that the Department presented three older mobile home
sales as market support for its cost approach valuation at the CTAB hearing. Ex.
E; MTAB Hr 'g Tr. 45:13-46:15. The Department did not use those sales to
calculate the Subject Property's value. Ex. E; MTABHr'g Tr. 45:13-46:15. Mr.
Pritchard agreed that the Taxpayer's comparable mobile homes were newer and
larger than the Subject Property. Ex. E; MTAB Hr 'g Tr. 49:6-11.
22. Mr. Pritchard reviewed but did not rely on the Taxpayer's advertisements in
valuing the Subject Property because the listings postdated the January 1,2024,
lien date. MTAB Hr 'g Tr. 46:23-47:8. Mr. Pritchard further testified that the
advertisements reflected asking prices rather than verified sale prices, involved
different markets, and did not reliably establish the listed properties' conditions or
ultimate sale prices. Id.
23. Mr. Pritchard testified that the Department's proposed $9,420 value qualifies the
Subject Property for the statutory exemption applicable to certain older mobile
homes valued below $10,000. Ex. D; MTAB Hr'g Tr. 44:24-45:1. Mr. Pritchard
testified that the exemption would eliminate approximately $37 in property tax,
while separate landfill and television-district fees would remain. MTAB Hr 'g Tr.
45:2-12.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
24. Mr. Pritchard testified that the Department's condition, desirability, and utility
scale considers a rating of six to be fair and five to be poor. MTAB Hr 'g Tr. 54:4-
10. Mr. Pritchard testified that reducing the Subject Property's condition,
desirability, and utility ratings from fair to poor would reduce its value. MTAB
Hr'gTr.55:6-12.
25. Ms. Severson testified that a mobile home rated poor may, but does not always,
remain livable. MTAB Hr'g Tr. 32:1-5. Mr. Pritchard testified that poor condition,
desirability, and utility ratings reflect greater obsolescence, physical deterioration,
and deferred maintenance and may still apply to a potentially livable home. MTAB
Hr'gTr.54:l-5.
JURISDICTION AND STANDARD OF REVIEW
26. 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 CTAB's decision to the
MTAB. Therefore, this Board maintains jurisdiction to hear and decide this matter.
Mont. Code Ann. § 15-2-301.
27. When reviewing a county tax appeal board decision under Mont. Code Ann. §15-
2-301, MTAB acts as a quasi-appellate body with authority to supplement the
record and is limited to issues properly preserved for appellate review. O'Brien v.
Mont. Dep't of Revenue, 2026 MT 132, ^ 72.
28. The Board's order is final and binding upon all parties unless changed by judicial
review. Mont. Code Ann. § 15-2-301(6).
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
CONCLUSIONS OF LAW
29. To whatever extent the following conclusions of law may be construed as findings
of fact, they are incorporated accordingly.
30. "All taxable property must be appraised at 100% of its market value..." Mont.
Code Ann. § 15-8-111.
31. "[1]n connection with any appeal under [Mont. Code Ann. § 15-2-301], the
Montana board is not bound by common law and statutory mles 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).
32. 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 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).
33. The Taxpayer bears the burden of proving the error of DOR'S decision. Farmers
Union Cent. Exch. v. Dep't of Revenue, Til Mont. 471, 476, 901 P.2d 561, 564
(1995); Western Air Lines, 149 Mont. at 353, 428 P.2d at 7.
34. '"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,
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
47); see Northwest Land & Dev. v. State Tax Appeal Bd., 203 Mont.313,317, 661
P.2d 44, 47 (1983).
35. "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 Udallv. Tollman, 380 U.S. 1,
16 (1965)).
36. The term "improvements" includes all buildings, structures, fences, and
improvements situated upon, erected upon, or affixed to land. Mont. Code Ann. §
15-1-101(1X0.
37. 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. Albrightv. State, 281 Mont. 196, 208-09, 933 P.2d 815, 823 (1997).
DISCUSSION
38. The Taxpayer bears the burden of proving that the Department's valuation is
incorrect. The Board concludes that the Taxpayer met that burden in part. The
Department's cost approach provides a reasonable starting point, but the evidence
supports lower ratings for condition and property desirability than the Department
applied. Mr. Danno's advertisements do not provide a reliable alternative
indication of the Subject Property's market value. The advertisements postdate the
January 1, 2024, lien date, reflect asking prices rather than verified sale prices,
concern properties in different markets, and provide insufficient information to
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
reliably compare the properties' condition and terms of sale. The Board therefore
gives the advertisements limited weight and does not rely on them to establish the
Subject Property's market value.
39. The Department's proposed $9,420 value reflects several corrections made during
this appeal. The Department removed the pole building, enclosed porch, and
prefabricated wood stove from the M-PRC. The calculation applies a low grade
and a 17-percent-good factor. Mr. Pritchard testified that changing the effective
year would not produce additional age-based depreciation. The Board accepts the
cost approach as appropriate and finds no basis to change the low grade or apply
additional age-based depreciation.
40. The Department rated the Subject Property's condition and property desirability as
fair. The Board finds that the condition and property desirability ratings do not
adequately reflect the Subject Property's physical condition and deterioration. Mr.
Danno testified that the roof leaks, some windows are boarded, and the tires are
unusable. Mr. Danno's uncontested testimony and photographic evidence show
that the interior is damaged and that insulation is fastened to the interior walls. The
Board finds the photographs persuasive because they depict holes in the walls and
significant staining on the interior walls and ceiling of the mobile home. Ms.
Severson testified that the photographs did not change her opinion of value, and
Mr. Pritchard testified that the photographs he received were too dark to clearly
establish the interior condition. The Board finds that the photographs admitted into
the record are sufficiently clear to corroborate Mr. Danno's testimony concerning
substantial deterioration and wear. Although Ms. Severson believed the existing
valuation inputs accounted for the deterioration and obsolescence, the Board finds
that the fair ratings did not adequately reflect the Subject Property's demonstrated
condition.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
41, Neither Department witness inspected the interior in person, and Ms. Severson did
not inspect the roof or tires. Ms. Severson nevertheless retained the fair rating
because she believed the low grade, effective year, and existing depreciation
already accounted for deferred maintenance and obsolescence. Those inputs
address construction quality and depreciation, but they do not eliminate the need
for condition and property desirability ratings to accurately reflect the Subject
Property's demonstrated physical and functional characteristics.
42. The evidence supports reducing the Subject Property's condition and property
desirability ratings from fair to poor. A poor condition rating recognizes the
Subject Property's physical deterioration and deferred maintenance. A poor
property desirability rating recognizes the mobile home's deteriorated aesthetic
appeal, diminished market attractiveness, and the effects of deferred upkeep on its
overall appearance. The mobile home remains occupied, provides kitchen and
bathroom facilities, is connected to a septic system, and produces monthly rent.
The Subject Property is impaired but remains livable and has continuing utility.
The Board therefore retains the fair utility rating.
43. The Department shall recalculate the Subj ect Property ' s value using ratings of
poor for condition and property desirability. The Board declines to adjust location
desirability because the Department rated the location as average and the record
does not establish that the geographic location itself is inferior. The Taxpayer's
$2,000 estimate does not establish a market-derived adjustment warranting a
separate dollar-for-dollar deduction. The poor ratings for condition and property
desirability adequately recognize that circumstance together with the Subject
Property's physical and functional limitations.
44. Therefore, the Board modifies the CTAB's determination and directs the
Department to recalculate the Subject Property's value using ratings of poor for
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUST v. STATE OF MONTANA, DEPARTMENT OF
REVENUE
the condition and property desirability, while retaining a fair rating for utility and
an average rating for location desirability.
BEFORE THE MONTANA TAX APPEAL BOARD
EVANF. DANNO REVOCABLE LIVING TRUSTv. STATE OF MONTANA, DEPARTMENT OF
REVENUE
ORDER
45. The decision of the Flathead County Tax Appeal Board is modified.
46. The Department shall revise its records and recalculate the value using poor
ratings for condition and property desirability.
Dated this 25th day of September 2026.
?P^4 <&	^
f—^	%	A:
0
SEAL
^-^
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^	^ ^	^
^T^OF
^
Travis Brown, Chainnan
illinoff, Member
ber	[Stopher IS^drphy,
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 Revenueshall
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).
BEFORE THE MONTANA TAX APPEAL BOARD
Certificate of Service
I certify that I caused a tme and correct copy of the foregoing Findings of Fact, Conclusions
of Law, Order, and Opportunity for Judicial Review to be sent by email and United States
Mail via Print & Mail Services Bureau of the State of Montana on September 25, 2026, to:
Evan-F. Danno
144 Highland Ridge Drive
Kalispell, Montana 59901
evandanno(%hotmail.com
Kristina K. Warren, Senior Tax Counsel
State of Montana, Department of Revenue
Legal Services Office
P.O. Box 7701
Helena, Montana 59604-7701
Kristina,warren(%mt.gov
Paula Gilbert
State of Montana, Department of Revenue
Property Assessment Division
P.O. Box 8018
Helena, Montana 59604-8108
Jamie Hadley
Flathead County Tax Appeal Board
800 Main, Room 302
Kalispell, Montana 59901
^ \y
/
Madison Ambrose Hall
Legal Administrative Assistaht
16

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