Assessment Review Board

Commission de révision de l’évaluation foncière

ISSUE DATE: June 16, 2017

FILE NO.: WR 143093

Assessed Person(s): John Kilgour and Christina Kilgour

Appellant(s): John Kilgour and Christina Kilgour

Respondent(s): Municipal Property Assessment Corporation (“MPAC”) Region 07

Respondent(s): Township of North Kawartha

Property Location(s): 2 Eels WAO CON 16 PT LOT 37 INCLUDES RP

Municipality(ies): Township of North Kawartha

Roll Number(s): 1536-020-203-09400-000

Appeal Number(s): 3173460, 3173461, 3173462 and 3173463

Taxation Year(s): 2013, 2014, 2015 and 2016

Hearing Event No. 638792

Legislative Authority: Section 40 of the Assessment Act, R.S.O. 1990, c. A.31, as amended

Heard: September 23, 2016 in Apsley, Ontario

APPEARANCES:

Parties	Representative
John Kilgour and Christina Kilgour	Self-represented
MPAC	Ron Donnelly
Township of North Kawartha	Dolores Wilson

DECISION OF THE BOARD DELIVERED BY WARREN MORRIS

INTRODUCTION

1The subject property is a 663 square foot (“sq. ft.”) seasonal/recreational cabin on a 0.82 acre waterfront site municipally known as 2 Eels Lake WAO. Access to the property is by water only.

2The appeals for the 2013, 2014, and deemed 2015 tax years were originally heard before the Assessment Review Board (the “Board”) by Member Robert Tchegus, and a decision was issued on September 23, 2015. In that decision, the Board supported MPAC’s recommended valuation of $170,000, however, in order to make the assessment equitable with the assessments of similar lands in the vicinity, the Board reduced the current value assessment (“CVA”) to $141,250. The Appellants filed a review of Member Tchegus’ decision to the Board’s Associate Chair, on the basis that evidence presented at the hearing was omitted and not considered by the Member in his CVA analysis. As well, the Appellants’ claimed that the Member made a miscalculation of the percentage difference between the 2008 and 2012 assessed values of the property. In his review decision, the Board’s Associate Chair concluded that factual errors and misapprehension of evidence by the Member impacted the decision. Consequently, the Board’s Associate Chair granted a rehearing of the matter.

3By the time of the rehearing on September 23, 2016, the appeals for the taxation years 2013 to 2016 were before the Board. MPAC had originally returned a CVA for the subject property of $185,000 but maintained their $170,000 CVA recommendation. The Appellants believed the assessment was too high, and brought two witnesses and 24 file folders of evidence to support their position.

4At the completion of the hearing, the Board reserved its decision.

ISSUE

5The issues are to determine the current value of the property, and to ensure that the current value is equitable relative to the assessed values of similar properties in the vicinity.

DECISION

6The Board finds that the current value of the subject property is $130,000.

7Further, the Board finds that there is no evidence before it leading to the conclusion that the current value, as determined above, requires an adjustment in accordance with s. 44.(3)(b) of the Assessment Act (“Act”).

8Accordingly, the assessment of the subject property for the 2013 to 2016 taxation years is reduced to $130,000 as follows:

Taxation Year	Section Number	Appeal Number	From Value ($)	To Value ($)
2013	40	3173460	185,000	130,000
2014	40	3173461	184,000	130,000
2015	40	3173462	170,000	130,000
2016	40	3173463	141,250	130,000

REASONS FOR DECISION

The Legislation

9Section 19.(1) of the Act states:

19.(1) Assessment based on current value. – The assessment of land shall be based on its current value.

10Section 1 of the Act defines “current value” as:

“current value” means, in relation to land, the amount of money the fee simple, if unencumbered, would realize if sold at arm’s length by a willing seller to a willing buyer.

11Section 19.2(1) of the Act states:

19.2(1) Valuation days – Subject to subsection (5), the day as of which land is valued for a taxation year is determined as follows:

1. For the 2006, 2007 and 2008 taxation years, land is valued as of January 1, 2005.

2. For the period consisting of the four taxation years from 2009 to 2012, land is valued as of January 1, 2008.

3. For each subsequent period consisting of four consecutive taxation years, land is valued as of January 1 of the year preceding the first of those four taxation years.

12Section 44.(3) of the Act states:

44.(3) Same, 2009 and subsequent years. – For 2009 and subsequent taxation years, in determining the value at which any land shall be assessed, the Board shall,

(a) determine the current value of the land; and

(b) have reference to the value at which similar lands in the vicinity are assessed and adjust the assessment of the land to make it equitable with that of similar lands in the vicinity if such an adjustment would result in a reduction of the assessment of the land.

MPAC’s Evidence

13MPAC presented six exhibits into evidence which included a Valuation Report, Market Analysis, Price Changes Over Time, an Equity Analysis, as well as rebuttal notes to the Appellant’s realtor’s opinion letter and a Comparable Property Report. In its evidence, MPAC primarily relied on four comparable sales that are summarized in the following Table:

Table 1

Sale	Address	Sale Date	Sale Price / Time Adj	Effective Frontage (feet)	Effective Site Area (acres)	Building Area (sq. ft.)	Year Built / Quality Rating
Subject Property	2 Eels Lake WAO			345	0.82	663	1948 / 4.0
A	28 Wolf Lake WAO	May 2011	$176,000 / $170,336	120	1.02	493	1967 / 4.5
B	37 Fire Route 55A	June 2011	$192,000 / $186,481	175	1.77	774	1962 / 4.0
C	1 Rathburn Lake Isla	May 2012	$190,000 / $194,394	245	1.17	650	1995 / 4.5
D	68 Eels Lake Island	Sept 2009	$175,000 / $178,176	230	1.06	735	1950 / 4.0

14The MPAC representative, Ron Donnelly, testified that he believed all four of the comparable properties are inferior to the subject property as all the comparables had smaller lake frontages. Mr. Donnelly stated that lake frontage is one of the biggest predictors of value for waterfront property. Further, Sales A, B, and C, were located on lakes that were smaller and therefore inferior to Eels Lake. Mr. Donnelly acknowledged that Sale D was the most comparable to the subject property although he maintained that it is still inferior to the subject property. Adding to its inferiority is the fact that Sale D does not have hydro connected at the property whereas the subject property does.

Based on all four sales of inferior properties selling for more than $170,000, Mr. Donnelly believes that a market value of $170,000 is reasonable.

Appellant’s Evidence

15The Appellant, John Kilgour, adduced evidence through submitting 24 file folders of documentary evidence and by questioning two witnesses, Peter Millard (real estate lawyer) and Ambrose Moran (realtor).

16Mr. Millard testified (consistent with his letter of legal opinion in folder 8) that the subject property has a number of deficiencies, the most significant being that the main structure on the property was built on a shoreline road allowance. Other issues included zoning, building code violations, illegal septic system, fire code violations, as well as problems with the windows, front door and floors. It was Mr. Millard’s opinion that any prospective purchaser would have difficulty obtaining a mortgage or insurance for the subject property.

17Mr. Moran testified (consistent with his letter dated August 22, 2016 in folder 7) that the property values on Eels Lake have not increased over the past 10 years. To support his proposition, he provided information on four Eels Lake properties, as follows:

Table 2

	Address	Sale Date	Sale Price	Other features	Comments
1	1090 Wilderness Island Trail	2005	$207,000	106 ft frontage, 3 bdrm.	Listed for sale 2010 to 2013; Did not sell. Last listing price $279,000
2	Wilderness Island Trail	Fall 2013	$201,000	111 ft frontage, 3 bdrm.	Listed in 2012 and 2013 for $239,000; 2012 CVA - $204,000;
3	79 Fire Route 74B	2007 2010	$284,500 $272,500	3 bdrm., road access	Listed in 2013 for $315,000 and $285,000 but did not sell
4	480 Fire Route 73B	2012	$150,000	2 bdrm., road access	2012 CVA $271,000

18Mr. Moran’s other conclusions were as follows:

• Marketability of the property is negatively affected by lack of compliance with current building code, fire code, zoning and septic compliance.

• Market demand for the Kilgour property is low based on its water access and modest cabin requiring major updating but constrained by zoning restrictions.

• That the only reliable comparison to establishing the current value of Kilgour property are island and water access only properties on Eels Lake.

• That in recent years, potential buyers have avoided Eels Lake based on media attention to drastic water reductions which stigmatize properties on Eels Lake.

19Mr. Kilgour’s testimony included a history of the subject property’s main building being located on a shoreline road allowance and the details involved with rectifying the issue. Currently, if the building was destroyed or otherwise needed to be rebuilt, it could not be done on the existing footprint. In order to achieve “legal non-conforming” status, permitting a rebuild on the same footprint, Mr. Kilgour would have to obtain and register on title a site-specific amendment to the zoning by-law. Mr. Kilgour estimated the cost to achieve this status would be approximately $6,000, which includes Township fees ($1500), a land survey ($1,200), services of a local planner to file and present By-Law Application to the municipality ($3,000) and registration of the amending by-law ($300).

20Mr. Kilgour presented further evidence of the cost to rectify the deficiencies for the subject property cottage. His estimates are as follows:

i. Front deck railing assembly, to fully comply with Ontario building code - $5,000

ii. Installation of a new septic system - $28,000

iii. Replacement of wood stove and chimney to meet fire code, including WETT Certificate inspection and issuance - $5,500

iv. Replacement and repair of windows - $5,000+

v. Replacement and fitting of front door - $250

vi. Refinishing of pine flooring - $4,250+

21In total, Mr. Kilgour estimates that it would cost at least $54,000 to rectify the deficiencies at the subject property to enable a market sale.

22Mr. Kilgour identified three comparable properties, all on Eels Lake WAO, the details of which can be found in folders B, C and D. The properties can be summarized as follows:

Table 3

Address	Sale Date	Sale Price	Frontage (feet)	Site Area (acres)	Building Area (sq. ft.)	Other
2 Eels Lake WAO (Subject Property)			590 (345 feet effective according to MPAC data)	0.96 acres or 35,719 sq. ft.	663	2 bdrm.; built in 1948; quality 4.0;
62 Eels Lake Island 11	Aug. 2011	$190,000	845 (472.5 feet effective according to MPAC data)	2 acres (1.97 acres according to MPAC’s data, or 85,813 sq. ft.)	770	2 + 1 bdrm.; built in 1930; quality 4.0; deep water frontage w/o weeds; 2012 CVA $161,000
77 Eels Lake Island 10			763 (105 feet effective according to MPAC data)	0.51 acres or 22,215 sq. ft.	560 (+ 2 bunkies of 96 sq. ft. each = 752)	2+2 bdrms. (2 bunkies); quality 4.0; deep water frontage w/o weeds; 2012 CVA $153,000
8 Eels Lake WAO	2003	$83,000	783 (376 feet effective according to MPAC data)	2.64 acres	944	built in 1954; quality 4.0; 2012 CVA originally returned $163,000, reduced to $120,000 by Request for Reconsideration (RFR)

23Mr. Kilgour made submissions that the water levels on Eels Lake sustain an eight to 10 foot annual average drop in water levels from May to the end of August each year. He presented an article from Cottage Life magazine which corroborated that Ontario lake water levels have generally been declining, and the article referenced the lakes that feed the Trent Severn Waterway as an example. Mr. Kilgour argued that his property value is impacted more than most others on the same lake due to his shallow shoreline. He also used a Cottage Life magazine article to argue that water access only (WAO) cottages are generally less valuable, with the exception of island properties, whose value can be more or less than road access cottage value, with private islands being more valuable than shared islands.

24While Mr. Kilgour agreed with MPAC that 68 Eels Lake Island (MPAC Sale D) is a useful sale for determining the value of the subject property, he took issue with MPAC’s description of the Sale D as being inferior. In cross-examining Mr. Donnelly, he disputed the square footage, claiming it to be 995.8 sq. ft. as opposed to the 735 sq. ft. presented by MPAC. Mr. Kilgour disputed MPAC data related to the number of outbuildings, claiming that there is a 120 square foot storage building, an outhouse, and a 108 square foot sleeping cabin not noted by MPAC. Although Mr. Donnelly stated that MPAC does not give value to outbuildings of less than 200 sq. ft., Mr. Kilgour questioned whether that meant they are of no value. Mr. Kilgour had Mr. Donnelly admit that all things being equal, a cottage with an additional 300 sq. ft. floor area would be more valuable. He also questioned MPAC’s knowledge of the superior quality cladding, siding and roof, to which Mr. Donnelly was either unaware or felt was roughly comparable to the subject property. Mr. Kilgour then questioned Mr. Donnelly’s assertion that by not having electric power, Sale D has a lower value. Mr. Kilgour stated during his cross-examination that there is an underwater electric cable servicing the island where Sale D is situated but that the owners have chosen to remain off the electrical grid for a number of reasons. Mr. Kilgour stated that the reasons for opting out of electricity include avoiding potential lightening strikes, power surges, blackouts, and inability to suspend service during the off season, and hydro electric rates being high. For these reasons, Mr. Kilgour stated that for these types of properties, having electric power would lower the value of the property.

25Mr. Kilgour presented many other pieces of documentary evidence in addition to his oral testimony to support his view that his cottage has limited market value, and certainly less value than Sale D. His arguments also include: i) all the deficiencies described by his witnesses, ii) the general poor condition of the subject property, iii) the poor shoreline, including steeper slope, low water levels and abundant seaweed growth, iii) the distance from the marina contributing to longer and more difficult access, iv) the fact that Eels Lake is a low value lake, v) less privacy from neighbours, vi) inferior accessibility from the lake, vii) inferior views, and viii) inferior finishings.

Analysis - Current Value

26The best indicator of current value is an arm’s length and market tested sale of the subject property on the valuation date, January 1, 2012 or close to it. If, as in this case, no such transaction took place near the valuation date, the next best measure of current value is the arm’s length and market tested sales of comparable properties in the same vicinity and market on or close to the valuation date. To enable an estimate of value for the subject property to be derived from a comparable property there must be sufficient elements of similarity, in terms of location and physical factors such as total water frontage, lot area, building area, age/quality of construction and other features such as outbuildings and qualitative features, so as to enable a direct comparison to be made between the comparable property and the subject property. In the Board’s view, for lakefront seasonal properties, the key element to establish similarity is location, with the remaining elements (total water frontage, lot area, building area, age/quality of construction and other features such as outbuildings and qualitative features) being of diminishing significance in rank order, with water frontage being of the next most significance and “other features” being of the least significance.

27Prior to comparing the subject property to the market sales, it is important to note that the Appellant presented a substantial volume of evidence of the subject property’s deficiencies to show that it is inferior to the comparable sales. But the Appellant also presented dollar figures on some of the same deficiencies to argue that the current value should be reduced by the cost to remedy the deficiencies. In the Board’s view, it would be double counting and improper to use the same deficiencies to say that the current value is lower than a comparable sale, and then proceed to lower the assessment again by the value of the same deficiencies. For this reason, the Board will take a two-step approach to determine current value. First, it will compare the subject property to the relevant comparable sales as if none of the dollar-valued deficiencies (itemized in Paragraph [20] above) exist. Then the Board will examine the dollar estimates for remediation, and determine the amount of money, if any, is required to rectify the deficiencies. The remediation amount would then be deducted to arrive at a reasonable current value.

28Of the 11 properties presented in evidence (four from MPAC, four from the Appellant’s realtor, and three from the Appellant; see Tables above), there is one, Sale D at 68 Eels Lake Island (“68 Eels”), that stands out as being the most comparable to the subject property, and therefore will be given the most weight in determining current value. Prior to examining 68 Eels to determine whether it is inferior (as claimed by MPAC) or superior (as claimed by the Appellants) to the subject property, the Board will look at the other 10 properties presented at the hearing to determine what, if any, impact they have on determining current value.

29Sales A, B and C presented by MPAC, are all water access only seasonal dwellings located in Kawartha Highlands Provincial Park on lakes smaller than Eels Lake. The Board accepts the Appellant’s evidence that Eels Lake is significantly different than the lakes for Sales A, B and C, given that they are in a provincial park and are not subject to the vast drop in water levels that Eels Lake experiences. Given that location is the single biggest factor in arriving at comparability, and the significant distance from Eels Lake, it is the Board’s view that Sales A, B and C are not particularly useful as comparables and will therefore be given little weight.

30For the four property sales present by the Appellant’s witness Mr. Moran (see Table 2 above), it is difficult to determine the degree of comparability of any of them to the subject property. 1090 Wilderness Island Trail (Property 1), which sold in 2005 for $207,000, has a similar location and a smaller frontage relative to the subject property. Given that Property 1 was sold approximately seven years prior to the valuation date, coupled with the lack of other descriptors for the property, the Board is not inclined to consider this sale. The fact that Property 1 was listed for $279,000 in 2013, but did not sell, only tells us that its market value is likely less than $279,000. The second property on Wilderness Trail (Property 2) also has a similar location but smaller frontage than the subject property. Due to lack of detail in regard to the building, it is difficult to determine whether the $201,000 sale price in the fall of 2013 is reflective of the subject property’s market value. For this reason, Property 2 will be given little weight. For 79 Fire Route 74B and 480 Fire Route 73B (Properties 3 and 4), both have road access, which makes these properties significantly dissimilar to the subject property. As such, the Board does not find them useful and will give them no weight.

31For the three properties presented by Mr. Kilgour (see Table 3 above), none of them provide assistance for determining the current value of the subject property. 62 Eels Lake Island 11, which sold for $190,000 in August 2011, has a similar location, larger frontage, larger lot, and similar building size and quality to the subject property. According to Mr. Kilgour’s evidence, this property is vastly superior – 33 percent superior, in his view, to the subject property. However, according to evidence from MPAC, the sale was an estate sale among family members and the property was not exposed to the market. Given that the property was not exposed to the market, the sale price cannot be considered representative of the market and therefore is not meaningful for determining current value of the subject property. For the property at 77 Eels Lake Island 10, the Board accepts Mr. Kilgour’s evidence that this property appears superior to the subject property, as it is of a similar location, but occupies an entire island to itself, and has a better quality shoreline as well as superior structures (two guest cabins) on the property. The property had a 2012 assessed value of $153,000. There was no evidence of a market sale close to the valuation date. Market sales, as opposed to assessed values, are a far better indicator of current value. For this reason, the Board is giving little, if any, weight to this property when arriving at current value. Finally, 8 Eels Lake WAO, the property immediately adjacent to the subject property, was put forth by Mr. Kilgour as a comparable property. There was an $83,000 sale of this property that took place in 2003. Although the Appellant presented evidence by way of realtor, Mr. Moran, that the market values of properties have remained relatively constant over the past 10 years, the Board is not satisfied that a sale of 2003 is representative of the 2012 market. Mr. Moran presented only one property that sold twice over that period of time that indicated a slight price drop between 2007 and 2010 (see Property 2 in Table 2). The rest of Mr. Moran’s evidence of price stability over this period were inferences from listings, not sales. Since listings are not clear indications of market value, the Board rejects Mr. Moran’s conclusion that the market of 2003 is similar to the market of 2012. Generally the Board looks at sales of comparable properties that sold within one year of the valuation date, and on occasion will consider sales a few years further from the valuation date when other sales do not exist. But considering a sale from nine years prior to the valuation date is generally not constructive for determining current value. For this reason, the Board gives no weight to the 2003 sale of 8 Eels Lake WAO.

32The most comparable property is clearly 68 Eels, which sold in September 2009, just over two years prior to the valuation date. The most important element of similarity is location. The Appellant claims that 68 Eels is a superior location since it is in closer proximity to the marina, making access times shorter. It is the Board’s view that the location is relatively similar, and the very slight increase in travel time from the marina would not significantly impact value. The next most important element is water frontage. While the evidence shows that the length of shoreline is significantly shorter at 68 Eels, the Board accepts the Appellant’s evidence of the superior quality of the shoreline (primarily the deep water access), which offsets the inferior length, resulting in the frontage being overall relatively comparable. Other factors that have a lesser impact on value, such building size and quality, give a slight advantage to 68 Eels. The Board does not accept the Appellant’s argument that absence of hydroelectric connection adds value to a property. If anything, hydroelectric connection adds a little value. Based on the most important elements of comparability, the Board finds that 68 Eels is relatively comparable, but perhaps slightly inferior to the subject property. This conclusion is under the assumption that none of the deficiencies quantified in paragraph [20] are taken into consideration. For this reason, it is the Board’s view that $170,000 is a reasonable value for the subject property.

Deficiencies

33During the hearing, the Appellant presented estimated costs for restoring the cottage and obtaining compliance with fire code, building code, zoning (regarding legal non-conforming use) and environmental regulation. MPAC did not provide any evidence contrary to the Appellant’s cost estimates. A prudent potential purchaser would conduct some form of due diligence (legal search, survey review, home inspection, etc.) to determine whether there are any serious unexpected deficiencies at the property. The Board will examine each deficiency and attempt to determine its impact on value. The deficiencies can be put into categories: i) deficiencies that are so serious, virtually all potential purchasers would require rectification before purchasing; ii) deficiencies that are less serious, and when discovered, are items that a potential purchaser may or may not have rectified, but would certainly seek a reduction in the purchase price; and iii) deficiencies so minor as to have little or any impact on value. For category i) items, it is reasonable to deduct the full estimated cost of remediation. For category ii) items, because they are less serious and may or may not actually be remediated, only half of the estimated costs will be deducted. Category iii) items are essentially normal maintenance items that are common to many older structures. Prudent vendors of such properties would likely make these repairs. These commonly occurring repair issues are not considered defects, and as such the Board is not prepared to reduce the value of the property by the estimated cost of these repairs.

34Of the deficiencies presented by the Appellant, the fact that the building does not have status as a legal non-conforming use is a serious defect. The costs to rectify this legal defect, along with the cost to remedy the septic system, are items that clearly fall into category i). Thus, the $34,000 ($6,000 to obtain non-conforming use status and $28,000 for a compliant septic system, as per Appellant’s estimates) is a reasonable estimate and should be deducted for the purpose of remediating these serious defects.

35The remaining defects are items that are typically revealed through a home inspection. Some of these defects may appear serious, such as the fireplace not meeting fire code, railings not meeting building code. However, in older structures such as the subject property, they are common. Prospective purchasers often decide to proceed with a purchase after negotiating a discount, without ever rectifying issues. For these items, the Board is satisfied that a reduction of $5,250 (($5,000 deck railing + $5,500 stove) x 50 percent) is warranted. The other items listed as deficiencies are merely poor maintenance items (windows, front door, and scratched floors) which are also common issues in older cottages. For this category, no deduction is granted.

36In conclusion, it is the Board’s view that a deduction for remediation costs of $39,250 (composed of $34,000 in category i), and $5,250 in category ii)) is warranted. The Board has found that $170,000 is a reasonable market value for the subject property, if the substantial deficiencies were remedied. Thus, after the reduction for remediation costs, the Board finds the current value of the subject property to be $130,750 rounded down to $130,000.

Equity

37The Act requires the Board to address the issue of equity by having reference to the assessment of similar lands in the vicinity of the subject property. The Appellant has the burden of proving that the CVA is not equitable relative to similar lands in the vicinity of the subject property.

38The most common method of showing general underassessment of similar properties in the vicinity is to find properties that have sold and compare them to the CVAs. Dividing the CVA by the sale price yields a figure known as the Assessment to Sale Ratio, or “ASR”. The Appellant presented evidence of the CVA for five properties (two from Table 2 and three from Table 3 above) in the vicinity of the subject property. The CVAs for both of the properties presented in Mr. Moran’s opinion letter (Table 2), were higher than the sale prices, indicating that both properties were over assessed, the properties having an ASR of 1.01 and 1.80 respectively. For the three properties in Table 3, the Appellant stated that all three properties were superior, yet all had CVAs lower than the $170,000 CVA recommended for the subject property. But with a CVA of $130,000, only one property had a lower CVA than the subject property.

39MPAC presented an Equity Analysis submitted as Exhibit 4. The Equity Analysis consisted of the assessment and time adjusted sales of 30 similar properties in the vicinity of the subject property, all sales which took place in 2009, 2010, 2011 or 2012. MPAC determined the median ASR to be 0.98, which indicates that similar properties in the vicinity are generally slightly under assessed by approximately two percent. Consequently, MPAC concluded that an equity adjustment is not warranted.

40The Board considered the evidence presented by the Appellant as well as MPAC’s Equity Analysis. The purpose of s. 44(3)(b) is to ensure that if a property type in a particular area is generally being given assessments below the market value, then similar properties in the vicinity are also entitled to be under assessed. Equity does not mean that the Appellant is entitled to an assessment that is equally below market value as any of their neighbours.

41The evidence, both from the Appellant and MPAC, shows that for the most part, assessments of similar properties in the vicinity of the subject property are just as likely to be over assessed as they are to be under assessed. Therefore, the Board is satisfied that an equity adjustment is not warranted.

CONCLUSION

42The assessment of the subject property for the 2013, 2014, 2015 and 2016 taxation years is reduced to $130,000 as given in the table below, and there is no evidence leading to the conclusion that the current value, as determined above, requires an adjustment in order to make the assessment equitable with similar property in the vicinity.

Taxation Year	Section Number	Appeal Number	From Value ($)	To Value ($)
2013	40	3173460	185,000	130,000
2014	40	3173461	184,000	130,000
2015	40	3173462	170,000	130,000
2016	40	3173463	141,250	130,000