Palo Pinto County Appraisal District
Appraisal Standards Review Follow-Up Report
April 13, 2009
Mr. Carlton Stagner, Board Chairman
Ms. Donna E. Rhoades, Chief Appraiser
Palo Pinto County Appraisal District
P.O. Box 250
Palo Pinto, Texas 76484-0250
Dear Chairman Stagner and Chief Appraiser Rhoades:
This letter constitutes the Comptroller’s follow-up review of the Appraisal Standards Review (ASR) of the Palo Pinto County Appraisal District (Palo Pinto CAD) originally released in October 2007. We commend the cooperation of Palo Pinto CAD’s board, chief appraiser and staff in conducting this follow-up review.
CADs play an integral part in setting property values because they have the statutory responsibility for determining local property values, which in turn affect funding to public schools — a critical part of the state’s tax and education policies.
The ASR made three mandatory recommendations and six optional recommendations to help Palo Pinto CAD achieve accurate local value in the annual Property Value Study (PVS) and improve operations. The Comptroller acknowledges the work Palo Pinto CAD has performed over the last year. The CAD has completed mandatory recommendation 3 and 4 of the six optional recommendations. These completed recommendations can assist the CAD in improving its staffing, management and appraisal practices.
We also reviewed the implementation of the remaining mandatory recommendations. While some work has been done, Palo Pinto CAD has not fully implemented recommendations 1 and 2. Enclosed is more detail on what the CAD still needs to do.
This letter is available on our Window on State Government Web site at www.window.state.tx.us/taxinfo/proptax/cadreports/asr/palopinto01/.
I hope this information is helpful. Please let us know if we can be of any further assistance.
Sincerely,
Susan Combs
Enclosure
cc: Superintendent and Board of Trustees, Gordon Independent School District;
Graford Independent School District; Mineral Wells Independent School District;
Santo Independent School District; Strawn Independent School District; and
Palo Pinto Independent School District
Palo Pinto CAD Board of Directors
Palo Pinto County Appraisal District
Appraisal Standards Review Follow-Up Report
What Remains to Be Done
The Comptroller’s office will continue to monitor Palo Pinto CAD’s progress toward meeting the state’s legal requirements. The following outlines steps Palo Pinto CAD still needs to take.
RECOMMENDATION 1:
Adopt and implement a comprehensive, written biennial reappraisal plan in compliance with Property Tax Code Section 25.18(b) and USPAP Standard 6.
Palo Pinto CAD provided the Comptroller’s Property Tax Assistance Division (PTAD) with copies of:
- Palo Pinto Appraisal District Reappraisal Plan, 2009 & 2010, adopted on Aug. 12, 2008;
- Palo Pinto Appraisal District SB 1652 Biennial Reappraisal Plan for the Annual Appraisal for Ad Valorem Tax Purposes of Real Estate and Income Producing Personal Property for Tax Years 2007 and 2008, approved on Sept. 6, 2006; and
- SB 1652 Biennial Reappraisal Plan or Ad Valorem Tax Purposes of Mineral, Industrial, Utility and Related Person Property for Tax Years 2007 and 2008, prepared by Pritchard & Abbott, Inc. and printed on Aug. 11, 2006.
The first two items appear to be identical, except the 2009 & 2010 plan is missing page 11 and also does not include a calendar, as is attached to the 2007 and 2008 plan. The plans indicate, “the board of directors of [Palo Pinto Appraisal District] adopted a policy for the Chief Appraiser to reappraise all property in the district every two years.” Neither plan, however, identifies the properties it will appraise in which year. Moreover, neither plan identifies the categories of properties the CAD will appraise. Neither plan identifies market areas. The 2009 & 2010 plan does not include a schedule of tasks. The Pritchard & Abbott plan for complex properties is also missing a calendar and market areas.
To complete this recommendation, the Palo Pinto CAD must review its reappraisal plan and amend it to ensure it complies with Property Tax Code Section 25.18, specifically as it relates to defining and identifying property value in market areas; including the properties it will appraise each year; and providing a calendar of allocation of resources to complete the reappraisal. A copy of the revised reappraisal plan must be submitted to the Comptroller’s office no later than June 30, 2009.
RECOMMENDATION 2:
Maintain updates of the appraisal manual for use in valuing residential and commercial properties and rural land.
The CAD provided PTAD with a nearly two-inch-thick set of documents in lieu of an appraisal manual. It is a hodgepodge of items, including:
- depreciation and cost schedules;
- property classifications;
- copies of photographs;
- sections of Comptroller manuals;
- copies of Comptroller forms;
- excerpts from ASRs of other CADs, excerpts from other CADs’ reappraisal plans and excerpts from newspaper articles;
- lists of taxing entities in the CAD and their tax rates;
- a schedule for the 2008 reappraisal; and
- various other pieces of information.
While all the information is helpful, its utility is minimized by its lack of organization. Bringing together various items does not make a manual. The items need to be organized in a manner that they are useful to CAD appraisers. A manual should have a table of contents; it should be organized into usable sections; each section should include clear descriptions of the purpose of the information; instructions for using it in the appraisal process; and pages should be numbered.
The documents do not include “procedures for performing sales comparisons for residential or commercial properties and land (whether rural or commercial), and lacks procedures for the income capitalization approach,” limitations noted in the ASR.
To complete this recommendation, the Palo Pinto CAD must organize these documents into a useful manual with a table of contents, sections for various functions, introductory explanations and procedures for each function and page numbers. A copy of the organized appraisal manual must be submitted to the Comptroller’s office no later than June 30, 2009.