Does the “costs of sale” adjustment apply to values determined by the cost approach and income approach?
This, of course, is the hot question of the day. Years ago, the court held in Bystrom v. Equitable Life Assur. Society that a costs of sale adjustment to a value arrived at by the income approach was improper because subsection (8) could only be applied if there had been an actual sale of the property. Fast forward to January 2011, when the Florida Department of Revenue issued PTO Bulletin 11-01 , advising all county value adjustment boards that they may make cost of sale adjustments to values determined by any of the three traditional approaches (cost, income, or sales comparison). This came on the heels of the DOR issuing VAB training materials that indicated that the eighth factor should result in a value less than fair market value. Many Property Appraisers take issue with the DOR’s interpretation and contend that it contravenes established Florida law. Hillsborough County Property Appraiser Rob Turner has filed a challenge to the DOR’s VAB training materials, asking that they be d
