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Case No. 19-0674

Stateline Cooperative
v.
Iowa Property Assessment Appeal Bd., and Emmet County Board of Review

Plaintiff in action for judicial review appealed a district court ruling which affirmed administrative decisions by the Iowa Property Assessment Appeal Board (IPAAB) concerning a property assessment made by the Emmet County Board of Review (ECBR). On appeal, plaintiff contended (1) the district court was without jurisdiction to consider ECBR’s cross-appeal of IPAAB’s decision on judicial review because it was untimely, (2) the district court erred by affirming IPAAB’s decision that certain structures on plaintiff’s property are not exempt from taxation as “[m]achinery used in manufacturing establishments” pursuant to Iowa Code sections 427A.1(1)(e) and 427B.17(3) (2014), and (3) the court erred in finding plaintiff did not establish the value of the exemption associated with the structures. ECBR cross-appealed, arguing its assessment was correct. The court of appeals affirmed on ECBR’s cross-appeal and affirmed in part and reversed in

County:
Emmet

Resisters

Stateline Cooperative

Applicants

Iowa Property Assessment Appeal Bd., and Emmet County Board of Review

Attorneys for Resisters

Brant D. Kahler
Adam C. Van Dike

Attorneys for Applicants

Bradley O. Hopkins
Jessica Braunschweig-Norris

M. Brett Ryan

Court of Appeals

Court of Appeals Opinion

Opinion Number:
19-0674
Date Published:
Nov 04, 2020
Summary

            Appeal from the Iowa District Court for Emmet County, Don E. Courtney, Judge.  AFFIRMED IN PART, REVERSED IN PART, AND REMANDED ON APPEAL; AFFIRMED ON CROSS-APPEAL.  Heard by Mullins, P.J., and May and Schumacher, JJ.  Opinion by Mullins, J.  (27 pages)

            StateLine Cooperative (StateLine) appeals the district court’s judicial-review ruling affirming the Iowa Property Assessment Appeal Board’s (IPAAB) administrative decisions following its review of the Emmet County Board of Review’s (ECBR) property-assessment determination.  StateLine argues (1) the district court lacked jurisdiction to consider the ECBR’s cross-appeal of IPAAB’s decision on judicial review, (2) the court erred in affirming IPAAB’s decision that certain structures were not exempt from taxation as “[m]achinery used in manufacturing establishments” pursuant to Iowa Code sections 427A.1(1)(e) and 427B.17(3) (2014), and (3) the court erred in concluding StateLine did not meet its evidentiary burden to value the exemption associated with the structures.  The ECBR cross-appeals, essentially arguing its original assessment was made in accordance with the Iowa Real Property Appraisal Manual and was therefore correct.  OPINION HOLDS: We conclude some of the property constitutes machinery used in a manufacturing facility, which is exempt from taxation.  We reverse the district court’s affirmance of the IPAAB on that point.  Because we find sufficient evidence in the record to reach values of the claimed exemptions, we conclude the IPAAB and court erred when they declined to do so.  We provide valuations for the items we find exempt from taxation, and we remand to the district court for entry of an order consistent with this opinion.

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