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Conclusions of Law for Petition 2021-00208: <br />Conclusions of Law <br />The Property Appraiser's Office presented reasonable evidence leading to a credible <br />indication of value. Key elements of this consideration are as follows: <br />1. Cost Approach data is developed, with both the Sales Comparison Approach and the <br />income Approach, considered not being applicable nor capable of reasonable <br />development, <br />2. The PAO utilizes shorter lives, based upon its own market research, as compared to <br />DOR provided lives and/or ASA developed lives. <br />3. The PAO astutely indicates that the Cost Approach does not consider either functional <br />or economic obsolescence, nor did it apply additional depreciation factors in this regard. <br />4. Depreciation factors are based upon the Marshall Valuation Service age/life table, <br />considered by the appraisal industry as being a reasonable indication of "installed" <br />remaining value. <br />5. Neither functional. obsolescence nor economic obsolescence factors, prior to <br />addressing Covid-19 issues, were developed. <br />6. The PAO. did not address any possible economic obsolescence effect of the Covid-19 <br />pandemic, other than offering information concerning how the State of Florida dealt with <br />such issues. <br />7. Overall, the value information developed by the PAO is considered reasonably <br />persuasive <br />The Petitioner presented evidence relating to the values without consideration of the <br />Covid-1.9 pandemic, as well as considering the possible level of economic obsolescence <br />resulting from the pandemic. Key elements of this consideration are as follows: <br />1. The Petitioner states that the PAO analysis does not include all forms of depreciation. <br />However, the PAO does state in its evidence that neither functional obsolescence or <br />economic obsolescence has been applied in its analysis. <br />2. The Petitioner extensively relates valuation information from a number of respected <br />sources (as previously noted). Such information is considered generally reasonable <br />guidance within the profession. <br />3. The Petitioner applies its essentially straight-line age/life factors, as compared to the <br />age/life curve utilized by the PAO, the latter PAO factors being considered to more <br />appropriately reflect physical deterioration of installed tangible property. <br />4. The Petitioner relies heavily upon information provided by PTRS, an independent <br />consulting firm, for its development of its age/life factors, as well as Remaining <br />Obsolescence Factors. However, there is not clearly provided or sufficient asset detail <br />information in this regard. <br />5. Relating to the possible effect of Covid-l9 causing additional economic obsolescence, <br />the Petitioner's information is not acceptably developed. As has been noted the PAO <br />requested from Buckhead Beef (not its parent Sysco) detailed financial and production <br />information in this regard. Such requested data was not provided. Further, the PAO <br />requested access to the facility, but such access was denied. Lastly, and of significant <br />-122- <br />2021-00205 Page 6 of 7 <br />