Michela Anne Gossage and Nathan Thompson v. Municipal Property Assessment Corporation Region 05, 2026 CanLII 32980

Tribunals Ontario

Tribunaux décisionnels Ontario

Assessment Review Board

Commission de révision de l’évaluation foncière

ISSUE DATE:

April 08, 2026

FILE NO.:

WR 190142

Assessed Person(s):

Michela Anne Gossage; Nathan Thompson

Appellant(s):

Michela Anne Gossage; Nathan Thompson

Respondent(s):

Municipal Property Assessment Corporation Region 05

Respondent(s):

Central Frontenac Township

Property Location(s):

481 Westport Road

Municipality(ies):

Central Frontenac Township

Roll Number(s):

1039-040-010-00706-0000

Appeal Number(s):

3537561, 3537606 and 3548756

Taxation Year(s):

2024, 2025 and 2026

Hearing Event No.:

790474

Legislative Authority:

Sections 34, 36 and 40 of the Assessment Act, R.S.O. 1990, c. A.31

APPEARANCES:

Parties

Counsel/Representative

Michela Anne Gossage Nathan Thompson

Tonya Brown

Municipal Property Assessment Corporation

Kalin Doucet

Central Frontenac Township

No one appeared

HEARD:

January 15, 2026, by video conference

ADJUDICATORS:

Kenneth Audziss, Member Rema El-Tawil, Member

DECISION

OVERVIEW

1Michela Anne Gossage and Nathan Thompson, (collectively the “Appellant”), are the owners of a residential property located at 481 Westport Road in Central Frontenac Township (the “Subject Property”). The Appellant appealed the 2024 s. 34 supplementary assessment and the 2025 s. 40 annual assessment of the Subject Property to the Assessment Review Board (the “Board”) under the Assessment Act, R.S.O. 1990, c. A.31 (the “Act”) on the ground that the assessments are too high. Pursuant to s. 40(26) of the Act, the Appellant is deemed to have brought the same appeal in respect of the 2026 taxation year.

2Under s. 19(1) the assessment of land for purposes of municipal taxation is based on the land’s current value. Section 1 of the Act defines current value as, “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”.

3Pursuant to s. 19.2 of the Act, January 1, 2026, is the day on which the Subject Property is valued for these taxation years.

4The property is improved with a newly constructed single-family dwelling and attached garage that was constructed in 2024. It is not disputed that the parties commenced use of the property as of June 2024.

5For the 2024 taxation year, the Municipal Property Assessment Corporation (“MPAC”) issued an assessment, effective July 1, 2024, of the current value of the Subject Property.

6The Appellant argues that the current value of the Subject Property, effective July 1, 2024, should be $370,000. The Appellant did not raise equity as an issue.

7In this proceeding it is MPAC’s position that the correct current value of the Subject Property is $510,000 for the taxation years under appeal. MPAC asserts that no reduction is required to make the current value equitable with the assessments of similar properties in the vicinity.

8Central Frontenac Township is a party to these appeals but did not participate in the hearing.

9At the completion of the hearing, the Board reserved its decision.

Areas of Agreement

10Parties agree to the residential classification, the use of the direct comparison methodology, the lot area, the total building area, and the size of the attached garage.

Issues for the Hearing

11The issues to be determined are:

What is the correct current value of the Subject Property, as of the January 1, 2016, valuation day?
Is the current value as determined by the Board equitable in reference to the assessments of similar lands in the vicinity?

Result

12The Board finds that the correct current value of the Subject Property, as of the January 1, 2016, valuation day, is $510,000 (rounded).

13The Board finds that the assessment of the Subject Property is equitable with the assessments of similar properties in the vicinity, so no equitable adjustment is required.

14Accordingly, the Board determines that the correct current value for both the s. 34 assessment for the 2024 taxation year effective July 1, 2024, and the s.36 assessment for the 2025 taxation year effective January 1, 2025, is $510,000.

ANALYSIS

Description of Subject Property

15The Subject Property is a two-story single-family detached (not on water) residential dwelling built in 2024 located in the Township of Central Frontenac. It has 342.18 frontage along Westport Road and 420.42 of depth for an effective site area of 3.3 acres. It has a total building area (“TBA”) of 3,187 sq. ft., with construction quality of 6.5. The first floor contains 1,943 sq. ft., a second floor of 1,244 sq. ft., with no basement. It has a custom floor plan with three bedrooms, three bathrooms, one fireplace and in-floor radiant heat. The Subject Property has an attached garage with a TBA of 1,850 sq. ft. with a construction quality of 3.0. The Subject Property is 46 kilometres north of Kingston, 32 kilometres south of Sharbot Lake, and less than two kilometres to South Frontenac Township.

Issue 1 - What is the correct current value of the Subject Property, as of the January 1, 2016, valuation day?

16In accordance with s. 44(3)(a) of the Act, the first mandate of the Board is to determine “the current value of the land.” Section 1 of the Act defines current value as “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.” That is, the Board must determine what the Subject Property would have sold for in an arm’s length transaction on January 1, 2016, the valuation day set by the Act.

17The best evidence the Board can receive of current value is an arm’s length and market-tested sale of the Subject Property on the valuation day or close to it. If no such transaction took place, the next best measure of current value is arm’s length and market-tested sales of comparable properties located nearby, as close as possible to the legislated valuation day of January 1, 2016.

MPAC’s Evidence and Submissions

18MPAC presented the Board with five proposed comparable property sales. These five proposed comparable property sales were improved with residences built between 1989 and 2016. Their effective site areas range from 2.96 to 8.91 acres and building sizes from 1,672 sq. ft. to 3,454 sq. ft. In terms of quality of construction, the properties range between 6.0 and 7.5.

19The proposed comparable property sales sold either within the shoulder years of the valuation day of January 1, 2016, or within one year of the shoulder period and time adjusted to January 1, 2016. In addition, three of the comparable properties had additional sales between 2017 and 2020 that were time-adjusted to January 1, 2016; however, these sales were not used in the calculation of the median sale price per square foot. Had MPAC included these sales, the median sales per square foot would have been higher than $160.20 which MPAC relies upon. The details of MPAC’s proposed comparable properties sales are in Appendix 1 at the end of the decision.

20MPAC argues that Property Sale 2 is equivalent to the Subject Property while Property Sales 1, 3, 4 and 5 are inferior to the Subject Property. The time-adjusted sale price range (“TASP”) of these five proposed comparable properties is between $314,991 to $532,950 and that the correct current value of the Subject Property as of the valuation date is $510,000.

21MPAC’s opinion of the correct current value of $510,000 was obtained by applying the median adjusted sale price per square foot, for the five comparable property sales between May 1, 2014, and December 1, 2017, to the Subject Property’s square foot measurements resulting in a suggested value of $510,557 or $510,000 rounded down.

Appellant’s Proposed Comparable Properties and Submissions

22The Appellant’s representative presented the sale of six properties he submits are more appropriate comparable properties. His six proposed comparable properties were improved with residences built between 2005 and 2022. Their effective site areas ranged from 3.93 to 68 acres with building sizes ranging from 1,952 sq. ft. to 3,670 sq. ft. The Appellant’s appraisal evidence provides an opinion that the quality of construction ranged from inferior to superior with no specific quality number assigned. One property was listed as inferior, two properties as similar, and three properties as superior. The Appellant’s evidence included no time adjustments for any of the proposed comparable properties. The details of the Appellant’s properties are shown in Appendix 2 at the end of the decision.

23The Appellant’s expert asserts that the Subject Property is an average quality home constructed with average materials and contains mostly standard features. He does however acknowledge that ICF construction is “definitely an upgrade”. He further submits that in his opinion the property is an over-improvement for the area, citing its large size in a remote location.

24The 2023 building permit estimated a total value of $500,000 (on top of the value of the land), MPAC estimates the construction value of $484,500. When the Appellant was asked if he had any evidence to confirm the construction cost was materially different from MPACs original calculation, the Appellant stated that he, “estimates $460,000 in construction costs but does not have exact numbers.” Furthermore, when asked what he would sell his house for today, he said that he would “list the property for more than what he paid to build it in 2024.” The Appellant submits that the Board should put greater weight on location than the particulars of the building noting: “the emphasis appears to be placed on dwelling size and age, with much less regard for location. It is our professional opinion that this is a flawed methodology given that location is the most important variable for purchasers.”

Findings on Issue 1

Findings on MPAC’s Proposed Comparables

25In establishing their proposed comparable properties, MPAC considers five factors: location, lot dimensions, living area, age of property, quality of construction. Relying on market evidence, MPAC proposed five comparable properties in the vicinity, and provided the time adjusted factors used in determining the correct current value of the Subject Property of $510,000.

26MPAC’s list of proposed comparable properties includes two properties outside the shoulder years. The Board notes that if it were to exclude those two comparable properties, the median time adjusted sale price per square foot would significantly increase from $160.20 to $212.40. Under the circumstances and recognizing the merits of having a larger sample size, the Board accepts MPAC’s evidence including those two properties.

27When considering the specific characteristics of the Subject Property and the MPAC proposed comparable properties, the Board makes the following findings: (a) the proposed comparable properties are an average of 18 years older that the Subject Property; (b) photographic evidence supports MPAC’s characterization of the property as being of high quality design and construction, which makes it superior to the Appellant’s characterization of the Subject Property being an average quality home; (c) the Appellant provided no evidence to suggest the property was over improved, and (d) the attached garage of the Subject Property is also 1,200 sq. ft. larger than the average of 642 sq. ft. of the garages of the MPAC proposed comparables.

28The Board also notes that the sale values for MPAC’s proposed comparables were all time adjusted to the valuation date of January 1, 2016.

29Based on the above analysis and findings, the Board finds that all of MPAC’s proposed comparable properties are comparable.

30In reaching this conclusion, the Board has considered the Appellant’s submissions on the significance of location on property value; however, location is only one of five factors when determining current value. The Board finds that the proposed comparables chosen by MPAC are relevant considerations given their location relevant to the Subject Property.

31Considering the evidence provided by the two parties, the Board prefers the evidence of MPAC as it was the only evidence provided that was time adjusted to the valuation date of January 1, 2016.

Findings on the Appellant’s Proposed Comparables

32The Appellant provided six proposed comparable properties constructed between 2005 and 2022 with sales between February 2015 and October 2025. None of the sales provided were time adjusted to January 1, 2016. The Board does not find they are comparable properties because they were not time adjusted.

Findings on Current Value

33Based on the above analysis and findings, the Board accepts that MPAC’s analysis provides the best evidence respecting current value. Therefore, the Board finds that the correct current value is $510,000.

Issue 2 - Whether there should be an equitable reduction of the current value pursuant to [s. 44(3)](https://www.canlii.org/en/on/laws/stat/rso-1990-c-a31/latest/rso-1990-c-a31.html#sec44subsec3_smooth)(b) of the [Act](https://www.canlii.org/en/on/laws/stat/rso-1990-c-a31/latest/rso-1990-c-a31.html), and, if so, what the amount of this reduction should be?

34 Section 44(3)(b) of the Act directs that after determining current value:

… the Board shall, …

(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 and Submissions

35Although neither party raised the requirement of an equitable adjustment as an issue in this appeal proceeding, MPAC submitted an Assessment to Sale Analysis based on twenty-six property sales across Central Frontenac Township, which indicates a median Assessment to Sales Ratio (“ASR”) of 0.97.

36MPAC submits that the International Association of Assessing Officers Standards states that the level of appraisal for all properties should fall between 0.90 and 1.10. MPAC takes the position that equity is achieved if the median ASR falls between 0.95 and 1.05. As 0.97 falls within this range, MPAC submits that no equitable adjustment is required in this case.

Appellant’s Evidence

37The Appellant did not raise equity as an issue and did not provide any submissions.

Findings on Issue 2

38The Board finds that MPAC’s uncontested evidence supports the fact that no equity adjustment is required.

CONCLUSION

39The Board has found that the correct value of the Subject Property is $510,000 for the 2024 taxation year effective July 1, 2024, and the 2025 and deemed 2026 taxation years and no reduction of this value is required pursuant to s. 44(3)(b) of the Act.

ORDER

40The Board orders that the current value of the Subject Property for the 2024 taxation year, effective July 1, 2024, is $510,000.

41The Board orders that the current value of the Subject Property for the 2025 and the deemed 2026 taxation years is $510,000.

"Kenneth Audziss"

KENNETH AUDZISS

MEMBER

"Rema El-Tawil"

REMA EL-TAWIL

MEMBER

Assessment Review Board

Website: www.tribunalsontario.ca/arb

Appendix 1

Subject Property

Property 1

Property 1b

Property 2

Property 3

Property 4

Property 4b

Property 5

Property 5b

Roll Number

103904001000706

102904002001170

102904002006103

103904005001250

102904001008945

103908004001100

Address

481B WESTPORT RD

3037 FREEMAN RD

4220 SILLS BAY RD

2021 WAGARVILLE RD

102 COUNTRY WOODS DR

1183 CLEMENT RD

Neighbourhood

H01 - 332

L01 - 312

H01 - 332

L01 - 312

S01 - 379

Property Code & Description

(301) Single-Family Detached (Not On Water)

Distance in KM

13.3042

15.0466

15.0999

17.0709

22.671

Valuation

Current Value Assessment

$510,000

$361,000

$686,000

$376,000

$438,000

$285,000

Sale

Sale Date

2016-12-01

2020-08-11

2016-06-30

2017-12-01

2015-08-17

2018-07-20

2014-05-01

2017-12-14

Sale Amount

$439,522

$710,000

$550,000

$495,000

$455,000

$505,000

$279,000

$392,000

Time Adjusted Sale Amount

$411,832

$535,340

$532,950

$435,105

$467,285

$428,240

$314,991

$344,568

Time Adjusted Sale Ratio

0.8766

0.6743

1.2872

0.8642

0.9373

1.0228

0.9048

0.8271

246.31

320.18

154.30

160.20

212.40

194.65

147.40

161.24

Site

Effective Frontage (F)

342.18

150

676.33

683.23

Actual Frontage

312.11

150

676.33

211.1

454.58

Effective Depth (F)

420.42

750

568.07

Actual Depth

750

824.32

Effective Site Area (Acres)

3.3

2.96

6.11

4.04

8.91

Actual Site Area (Acres)

3.3

2.96

4.04

6.11

4.04

8.91

Effective Lot Size Unit of Measurement

Lot Size Unit of Measurement

Access

Right-Of-Way Access (F) Abuts Farm

Year-Round Road Access (U) Abuts Utility Box

Year-Round Road Access

Year-Round Road Access (T) Abuts Trailer/Camp/Mobile Home Park

Subject Property

Property 1

Property 1b

Property 2

Property 3

Property 4

Property 4b

Property 5

Property 5b

Abuts Variable(s)

(O) Gravel Road , (E) Exceptionally Treed/Wooded

(O) Gravel Road

N) 26% - 50% Treed , (6) 11% - 25% Swamp , (G) Topography - Slight Slope ,

(G) Topography - Slight Slope , (N) 26% - 50% Treed ,

On Site Variable(s)

(O) Gravel Road

(O) Gravel Road , (6) 11% - 25% Swamp

Water Service Code

Private Well

Sanitary

Septic Bed

Variance

Irregular

Hydro Code

Hydro Available

Residential Structure

Structure Code & Description

(301) Single Family Detached

Year Built

2024

2016

1989

2013

2007

2002

Structure Condition Code

Average

Quality of Construction

6.5

7.5

6.5

Full Storeys

1 1/2 Storeys

2 Storeys

Split level

No Split

Bedrooms

Baths

2.5

1.5

Fireplaces

Air Conditioning

Heating Type

In-Floor Radiant (Coils)

Forced Air

Driveway

Separate Or Private Driveway

Building Total Area (SF)

3,187

1,672

3,454

2,716

2,200

2,137

First Floor Area (SF)

1,943

1,146

2,570

1,259

1,840

1,129

Second Floor Area (SF)

1,244

526

884

1,457

360

1,008

Basement Type

Finished Basement - Average Quality

Basement Area (SF)

2,083

1,259

1,840

1,129

Finished Basement Area (SF)

937

Basement Height

Secondary Structure(s)

Subject Property

Property 1

Property 1b

Property 2

Property 3

Property 4

Property 4b

Property 5

Property 5b

Structure Description

(116) Attached Garage

(101) Detached Garage

(116) Attached Garage

(101) Detached Garage

(116) Attached Garage

Year Built

2024

2016

1989

2007

2002

Building Total Area (SF)

1,850

875

760

894

420

Quality of Construction

Structure Description

(101) Detached Garage

Year Built

2003

Building Total Area (SF)

720

Quality of Construction

Appendix 2

Subject Property

Comparable 1

Comparable 2

Comparable 3

Comparable 4

Comparable 5

Comparable 6

Desc.

Adj.

Desc.

Adj.

Desc.

Adj.

Desc.

Adj.

Desc.

Adj.

Desc.

Adj.

Address

481B Westport Rd Godfrey

9896 County Rd 38, Godfrey

10757 County Rd 38, Godfrey

145 Mallens Rd, Rideau Lakes

102 Country Woods Dr., Sydenham

4595 Florida Rd, Harrowsmith

3748 County Rd 1, Yarker

Data Source

N/A

MLS #K5280483

MLS #K5136982

MLS #X9185395

MLS #X9186018

MLS #9158120

MLS #9183829

Date of Sale

N/A

12-DEC-2015

13-FEB-2015

21-OCT-2015

25-OCT-2025

02-JUN-2016

28-JUL-2015

Sale Price

N/A

$325,000

$339,500

$300,000

$435,000

$420,000

$419,900

Days on Market

N/A

140

List Price

N/A

$349,900

$309,000

$449,900

$438,900

$424,900

KM from Subject Property

Location

Rural

Similar

Superior+/Downward+

Superior/Downward+

Site Dimensions/Lot Size

312.11’ x Irregular 3.3 Acres

450’ x Irregular 5.61 Acres/Downward

500’ x Irregular 12 Acres/Downward

400’ x Irregular 9.6 Acres/Downward

211’ x 824’ 3.93 Acres/Downward

Irregular 68+/- Acres/Downward

626.41’ x Irregular 4.89 Acres/Downward

Property Type

Detached

Detached (Log)

Detached

Detached (Log)

Design/Style

Two-Storey

One-Storey

One-and-one-half-Storey

Two-and-one- half-Storey

One-and-one-half-Storey

Two-Storey

One-and-one-half-Storey

Age/Condition

1/Good

18/Avg.+

Upward

20/Avg.+

Upward

Good

Avg.++ Upward

Avg.+ Upward

Avg.+Up-ward

Floor Area

3,187 sq. ft.

2,350 sq. ft. +/-

Upward

2,800 sq. ft. +/-

Upward

1,952 sq. ft.+/-

Upward

2,200 sq. ft.+/- Upward

3,670 sq. ft. +/- Downward

2,100 sq. ft.+/- Upward

Room Count

10 Total 3 Bedrooms

7 Total

3 Bdrms

7 Total

3 Bdrms

5 Total

2 Bdrms

7 Total

3+2 Bdrms

9 Total

4 Bdrms

6 Total

3 Bdrms

Bathrooms

2 Full 1 Partial

Upward

3F Downward

2F Upward

Basement

Nil

Full/ Unfinished

Downward

Similar

Nil

Upward

Full/ Finished/Walkout

Down-ward

Crawl

Full/ Unfinish-ed

Down-ward

Parking Facilities

1,850 sq. ft Attached

552 sq. ft. Att./432 sq. ft. carport

Upward

800 sq. ft. Quonset Hut

Upward

1,994 sq. ft. Detached

894 sq. ft./ Detached

Upward

1,200 sq. ft. Attached

Upward

560 sq. ft. Attached

Upward

Access

Right-of-Way

Private/ Downward

Private/Downward

Extras/Site

Average

Superior

Downward

Superior

Down-ward

Similar

Superior

Down- ward

Similar

Superior

Down- ward

Quality

Average

Similar

Superior

Similar

Interior

Superior

Proximity to Kingston

46.3 KM+/-

52.9 KM +/-

57.1 KM +/-

53.2 KM +/-

26.8 KM +/-

29.1 KM +/-

34.8 KM +/-

Overall

N/A

Inferior

Superior

Subject Property

Comparable 1

Comparable 2

Comparable 3

Comparable 4

Comparable 5

Comparable 6

Adjustments (Gross %, Net $)

Adjusted Values

$325,000

$339,500

$300,000

$435,000

$420,000

$419,000