Geraldine H. Pearson - Page 18

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               Petitioner's land is listed by the Clackamas County                    
          Department of Assessment and Taxation as four separate lots.  The           
          following chart shows the assessed values of the lots in 1974 and           
          1992:                                                                       
          Lot    Acres        1974 Assessed Value    1992 Assessed Value              
          1000   44.01            Not in record          $118,390                     
          1090    3.80                $300                    220                     
          1600   60.00              12,600                 11,100                     
          1690   40.00               7,680                  5,710                     
          147.81              20,580                135,420                           
               We cannot meaningfully compare these figures because the               
          record does not contain the 1974 assessed value for lot 1000.               
               Petitioner testified that the assessed value of her farm               
          increased by $319,490 from 1974 to 1994.  Petitioner's                      
          calculation, however, mixes apples with oranges.  Petitioner                
          subtracted the assessed value for 1974 from the 1994 "real market           
          land value".  While the record does not define "real market land            
          value", we know that it is different than assessed value because            
          the tax statement issued by the Clackamas County Tax Collector              
          lists these values separately.                                              
               Even if petitioner's land appreciated by $319,490 from 1974            
          to 1994, petitioner has not shown that amount exceeded her                  
          losses.  Petitioner's net losses from 1985 to 1993 were $178,486            
          not counting depreciation and $244,178 counting depreciation.               
          The record does not show the amount of petitioner's losses before           
          1985.  We do not speculate as to the amounts of petitioner's                
          losses before 1985, but we note that petitioner had losses in 36            





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