The appellant appealed supplementary property assessments for the 2014, 2015, and 2016 taxation years, arguing that the value of post-purchase improvements had already been considered in a prior Board decision that set the property's value at $1.6 million, and that issue estoppel should apply.
The Assessment Review Board found that the prior decision did not address the value of the improvements, so issue estoppel did not apply.
The Board accepted the appellant's evidence that the improvements cost $223,000, adding this to the $1.6 million base value to determine a total current value of $1,823,000 for the 2015 and 2016 taxation years, and reduced the supplementary assessments accordingly.