Nestle USA, Inc. v. Madison County Assessor
CourtIndiana Tax Court
Date FiledSeptember 23, 2026
Docket25T-TA-00020
JudgeJudge McAdam
StatusPublished
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Full Opinion
ATTORNEYS FOR PETITIONER: ATTORNEYS FOR RESPONDENT:
PAUL M. JONES, JR. BRIAN A. CUSIMANO
BRIGHAM E. MICHAUD MARILYN S. MEIGHEN
JONES PYATT LAW, LLC ZACHARY D. PRICE
Greenwood, IN Carmel, IN
Indianapolis, IN
IN THE
INDIANA TAX COURT
NESTLÉ USA, INC., )
) FILED
Petitioner, )
)
Sep 23 2026, 3:26 pm
v. ) Case No. 25T-TA-00020 CLERK
Indiana Supreme Court
) Court of Appeals
and Tax Court
MADISON COUNTY ASSESSOR, )
)
Respondent. )
ON APPEAL FROM A FINAL DETERMINATION OF
THE INDIANA BOARD OF TAX REVIEW
FOR PUBLICATION
September 23, 2026
MCADAM, J.
Nestlé USA, Inc. appeals from a final determination by the Indiana Board of Tax
Review and raises two issues common in property tax valuation disputes: the operation
of Indiana’s property tax burden-shifting statute and the proper weight for the Board to
assign to competing evidence. Both Nestlé and the Madison County Assessor provided
the Board with an appraisal of Nestlé’s industrial facility and both supported these
appraisals with expert testimony at the administrative hearing. The Board ultimately
found the Assessor’s appraisal to be the most persuasive evidence of value for each of
the six tax years at issue. However, the Board’s application of Indiana Code
§ 6-1.1-15-17.2—the now-repealed statute governing shifts in the burden of proof in
certain property tax appeals—prevented the Board from adopting the Assessor’s value
for every disputed year. For 2019 to 2021, the Board found neither party’s appraisal met
its burden and reverted the assessments to the 2018 assessment. For the 2018, 2022,
and 2023 assessments, the Board adopted the Assessor’s appraisal valuation. Nestlé
challenges both the Board’s application of Section 17.2 and the sufficiency of the
evidence it relied upon to adopt the Assessor’s values and to reject Nestlé’s values. The
Court finds that the Board correctly applied Section 17.2, made its findings based on
substantial evidence, and did not abuse its discretion. The Court affirms the Board’s
final determination in its entirety.
FACTS AND PROCEDURAL HISTORY
Nestlé owns an industrial building of approximately one million square feet
situated on roughly 183 acres in Anderson, Indiana. The facility is used to manufacture
coffee creamers and other ready-to-drink beverages. The facility has interstate and rail
access and houses a mix of food-grade and general manufacturing, warehouse, dock,
office, and utility space, a portion of which is chilled for cold storage. Most of the facility
was constructed in 2008, with smaller additions in later years.
The Madison County Assessor assessed the subject property as follows:
Tax Year Land Value Improvement Value Total Assessment
2018 $3,916,500 $44,648,400 $48,564,900
2019 $3,916,500 $46,901,800 $50,818,300
2020 $3,916,500 $47,556,600 $51,473,100
2021 $3,916,500 $48,028,100 $51,944,600
2022 $3,916,500 $50,234,000 $54,150,500
2023 $3,916,500 $50,238,500 $54,155,000
2
Nestlé appealed these assessments to the Madison County Property Tax
Assessment Board of Appeals (“PTABOA”), which issued determinations upholding the
values for tax years 2018 to 2022. Nestlé then appealed the determinations for 2018 to
2022 to the Indiana Board of Tax Review and later appealed the 2023 assessment after
the PTABOA failed to issue a determination within 180 days.
The appeals for all years were heard together before the Board during a
multi-day evidentiary hearing at which both parties presented appraisal testimony. At
the outset of the hearing, the administrative law judge asked the parties for any
argument on the burden of proof; Nestlé acknowledged that it bore the burden and the
Assessor concurred.
Both parties submitted expert appraisals to estimate the value of the subject
property. Nestlé’s appraisal employed a cost approach and a sales comparison
approach, but no income approach to value the property, and did not develop an
independent land value determination, instead concurring in the existing land
assessment. The Assessor’s appraisal employed the cost, sales comparison, and
income approaches and independently valued the land. Each appraisal certified
compliance with the Uniform Standards of Professional Appraisal Practice (USPAP),
and the two reached materially different opinions of value, with Nestlé’s yielding the
lower valuation for every year.
Tax Nestlé’s Reconciled Value Assessor’s Reconciled Value
2018 $32,000,000 $48,000,000
2019 $31,900,000 $50,000,000
2020 $31,500,000 $53,500,000
2021 $31,900,000 $55,500,000
2022 $33,300,000 $57,000,000
2023 $33,900,000 $55,000,000
3
The Board found that Nestlé’s appraisal was supported by only one reliable
approach to value—its sales comparison approach estimate—and that its conclusions
lacked support along several dimensions. Regarding Nestlé’s cost approach, the Board
concluded it had little persuasive value, explaining (i) that the appraisal did not
independently value the subject property’s land, (ii) that the case-study underlying the
appraisal’s external-obsolescence estimate was unverified and unsubstantiated, and (iii)
that the external-obsolescence estimate lacked evidence to support the combination of
data used by the appraiser. Regarding Nestlé’s sales comparison approach, the Board
found it to be only “marginally credible” because (i) most of the comparable sales were
much older than the subject property, (ii) the appraiser conceded that all but one was
inferior to it, and (iii) the appraiser made significant adjustments to the leased
comparables without ever comparing their lease rates to market rent. (Cert. Admin. R.
at 3001 ¶ 32.) Lastly, the Board found that the appraiser’s failure to develop an income
approach was inconsistent with the appraiser’s reliance on leased comparables in his
sales comparison approach.
Turning to the Assessor’s appraisal, the Board concluded that it was “reliable
evidence of value for each of the dates at issue.” (Cert. Admin. R. at 3017 ¶ 68.) The
Board explained that it presented three reliable approaches to value “with good quantity
and quality of data” and found that it provided “excellent explanations for [its]
adjustments.” (Cert. Admin. R. at 3013 ¶ 59, 3024 ¶ 88.) Regarding the Assessor’s cost
approach, the Board concluded it was “a reliable and persuasive estimate of the subject
property’s value for each of the dates at issue.” (Cert. Admin. R. at 3015 ¶ 63.) It
credited the appraiser’s independent land valuation, found that the depreciation
4
estimate “appropriately accounted for the physical condition of the property,” and
determined its obsolescence estimate was the “most reliable” in the record. (Cert.
Admin. R. at 3014–15 ¶¶ 60–63.) The Board also noted that the appraisals use of data
from its income approach in its cost approach “undercut[ ] the independence of [the]
cost approach.” (Cert. Admin. R. at 3014–15 ¶ 62.) Regarding the Assessor’s sales
comparison approach, the Board found that it was credible and probative though not
“particularly persuasive” because of the “lack of good comparable sales.” (Cert. Admin.
R. at 3016 ¶ 65, 3023–24 ¶ 86.) Finally, regarding the Assessor’s income approach, the
Board found it to be a reliable estimate while expressing reservations that the “depth” of
underlying data “was not ideal.” (Cert. Admin. R. at 3024 ¶ 87.)
The Board compared the two appraisals and concluded that the Assessor’s
appraisal supplied the most persuasive evidence of the subject property’s value in the
record. The Board found that “[n]either appraiser presented a single comparable that
reflected the subject property in all . . . aspects” because of its unique size, age, and
physical characteristics. (Cert. Admin. R. at 3022 ¶ 82.) It found the Assessor’s cost
approach to be the only reliable estimate between the two appraisals, driven in large
part by Nestlé’s failure to independently value the land and the relative strength of the
Assessor’s obsolescence adjustments. It found the Assessor’s sales comparison
approach superior to Nestlé’s but found that both appraisals were “not particularly
persuasive” because both “suffered from a lack of compelling data.” (Cert. Admin. R. at
3023–24 ¶ 86.) Finally, it rejected Nestlé’s contention that an income approach was
inappropriate and concluded that the Assessor’s valuation—the only one in the record—
was a reliable estimate.
5
Applying the governing burden-of-proof statutes, the Board adopted the values in
the Assessor’s appraisal for the 2018, 2022, and 2023 assessment years, but could not
do so for 2019 through 2021 because the burden had shifted. The Board found that the
Assessor’s appraisal did not exactly and precisely match the assessments for the 2019
through 2021 assessment years and therefore concluded that the Assessor did not
carry its burden to prove the assessment correct. It found that Nestlé met its burden of
production but not its burden of persuasion in those years, because the Assessor’s
appraisal persuaded the Board that Nestlé’s conclusion of value was incorrect. Because
neither party carried its burden of persuasion, the assessments for those years (2019 to
2021) reverted to the value the Board determined for 2018.
Nestlé timely initiated this original tax appeal, and the Court heard oral argument.
STANDARD OF REVIEW
This Court’s review of the Board’s final determinations is governed by Indiana
Code § 33-26-6-6, the provisions of which closely mirror those controlling judicial review
of administrative decisions under Indiana’s Administrative Orders and Procedures Act
(“AOPA”). The party seeking to overturn a final determination of the Board bears the
burden of demonstrating its invalidity. IND. CODE § 33-26-6-6(b) (2018). To prevail,
Nestlé must demonstrate that it has been prejudiced by a final determination that is
arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law;
contrary to constitutional right, power, privilege, or immunity; in excess of or short of
statutory jurisdiction, authority, or limitations; without observance of the procedure
required by law; or unsupported by substantial or reliable evidence. IND. CODE
6
§ 33-26-6-6(e); Lowe’s Home Ctrs., Inc. v. Monroe Cnty. Assessor, 160 N.E.3d 263,
268 (Ind. Tax Ct. 2020).
DISCUSSION
On appeal, Nestlé claims that the Board’s final determination should be
overturned for two principal reasons: first, it contends that the Board misapplied the
burden-shifting statute and, second, it argues that many of the Board’s conclusions
were outside its discretion or unsupported by substantial evidence. The Assessor
defends the Board’s valuation but advances two counterclaims of its own. It contends
that the burden-shifting statute should not have applied to the 2019 through 2021
assessment years because assessments based on structural improvements are
excluded and that it did not have the opportunity to discuss the burden-shifting
application at the Board’s administrative process. Before turning to Nestlé’s claim about
the evidentiary support of the Board’s findings, the Court will address both parties’
arguments regarding the burden-shifting statute.
I. The Board correctly applied Indiana Code § 6-1.1-15-17.2.
Because the Board’s decision in this appeal determined the subject property’s
assessment values for tax years 2018 through 2023, two different burden-shifting
statutes govern allocation of the burden of proof, but the parties argue about only one—
Indiana Code § 6-1.1-15-17.2. Previously, Section 17.2 explained the circumstances
which would shift the burden of proof from the taxpayer to the county. IND. CODE
§ 6-1.1-15-17.2 (2018). However, in 2022, the Indiana legislature repealed Section 17.2
and replaced it with Indiana Code § 6-1.1-15-20. Pub. L. No. 174-2022, § 34, 2022 Ind
Acts 2347–49. The parties and the Board all agree that this change leaves tax years
7
2018 to 2021 governed by the old statute and tax years 2022 to 2023 governed by the
new statute. (Cert. Admin. R. at 3017–18 ¶¶ 69–71; Pet’r’s Br. at 10; Resp’t Br. 11, 33.)
As neither party raises an argument challenging the Board’s application of Section 20,
the Court will focus its statutory analysis on Section 17.2.
Both parties take issue with the Board’s application of Section 17.2’s legal
framework and ask the Court to remand the case, but the parties disagree about what
Board action requires a remand. Nestlé argues that the Board exceeded its statutory
authority in its application of Section 17.2 to the facts in this case when it (1) used the
Assessor’s appraisal to evaluate Nestlé’s appraisal and (2) found that Nestlé’s appraisal
did not meet its burden while also finding that same appraisal was “sufficiently
supported” and a “credible opinion of value.” (Pet’r’s Br. 8.) The Assessor focuses on
the procedural aspects of the Board’s application of Section 17.2, claiming that the
Board (1) failed to correctly apply the law by ignoring the exclusion from Section 17.2,
which prevents burden shifting when the assessment is based on structural
improvements, and (2) abused its discretion by failing to give the Assessor the chance
to address the burden-shifting statute at the administrative level.
The Court finds none of these four arguments persuasive and will address
Nestlé’s challenges first before turning to the Assessor’s two alternative arguments.
A. The Board correctly applied Indiana Code § 6-1.1-15-17.2 by
examining all evidence to find that Nestlé did not carry its burden.
Nestlé first claims that the Board violated Section 17.2 by considering the
Assessor’s appraisal alongside Nestlé’s appraisal to determine whether Nestlé had met
its burden to “prove the correct assessment” for tax years 2019 through 2021. Nestlé
argues that, once the Board found the Assessor’s appraisal fell short of the burden of
8
proof because it did not exactly and precisely match the assessment, the burden shifted
to Nestlé and “the Board should have considered only Nestlé’s [a]ppraisal.” (Pet’r’s Br.
at 7.) From Nestlé’s perspective, Indiana Code § 6-1.1-15-17.2 does not allow the
Board to consider an assessor’s appraisal when evaluating whether the taxpayer has
met its burden of proof. The Court disagrees. The statute is silent on the question, and
an appraisal that is insufficient to prove “the assessment is correct” may still be
probative of the value of the subject property.
Subsection (b) of Indiana Code § 6-1.1-15-17.2 is the locus of the dispute. It is
straightforward and applies only to appeals when an assessment has increased by
more than five percent over the previous year. It provides:
[T]he county assessor or township assessor making the assessment has
the burden of proving that the assessment is correct in any review or
appeal under this chapter and in any appeals taken to the Indiana board of
tax review or to the Indiana tax court. If a county assessor or township
assessor fails to meet the burden of proof under this section, the taxpayer
may introduce evidence to prove the correct assessment. If neither the
assessing official nor the taxpayer meets the burden of proof under this
section, the assessment reverts to the assessment for the prior tax year[.]
IND. CODE § 6-1.1-15-17.2(b) (2018). The statute has three primary functions, two of
which directly alter the normal rules of property tax appeals: (1) The first reallocates the
initial burden of proof from the taxpayer to the assessor, reversing the normal rule
assigning the burden to the taxpayer as the one challenging the assessment. (2) The
second follows the normal appeal process, allowing the taxpayer to prove the correct
assessment. And (3) the third specifies that the default remedy is the prior year’s
assessment in the event that neither party meets their burden, reversing the normal rule
that would otherwise leave the challenged assessment in place. See Eckerling v.
Wayne Twp. Assessor, 841 N.E.2d 674, 677 (Ind. Tax Ct. 2006); Lake Cnty. Assessor
9
v. O’Day Holdings, LLC, 249 N.E.3d 677, 685 (Ind. Tax Ct. 2024); Madison County
Assessor v. Kohl's Indiana, LP, 272 N.E.3d 592, 600 (Ind. Tax Ct. 2025).
Indiana courts look to the plain language of statutory text to determine its
meaning. Indiana Alcohol & Tobacco Comm’n v. Spirited Sales, LLC, 79 N.E.3d
371, 376 (Ind. 2017). When interpreting statutes, a court must first decide “whether the
Legislature has spoken clearly and unambiguously on the point in question.” City of
Carmel v. Steele, 865 N.E.2d 612, 618 (Ind. 2007). “Clear and unambiguous statutes
leave no room for judicial construction” and do not require “any rules of construction.” Id.
Instead, the words of such a statute are understood in their “plain, or ordinary and
usual, sense” unless doing so would be “plainly repugnant to the intent of the legislature
or of the context of the statute.” IND. CODE § 1-1-4-1 (2026). Courts cannot expand or
contract the meaning of an unambiguous statute by reading in language to correct
supposed omissions or defects and may not substitute language that they feel the
legislature may have intended. United Parcel Serv., Inc. v. Indiana Dep’t of State
Revenue, 281 N.E.3d 97, 102 (Ind. Tax Ct. 2026).
The plain language of Section 17.2 does not speak to whether the Board may
consider an assessor’s evidence regarding the correctness of the assessment in
evaluating the taxpayer’s burden. Fidelity to the plain and ordinary meaning requires
equal accounting of what a statute does not say just as much as what it does say. See
ESPN, Inc. v. Univ. of Notre Dame Police Dep’t, 62 N.E.3d 1192, 1195 (Ind. 2016).
Section 17.2 addresses only the allocation of the burdens of proof and the default
remedy; there is nothing in the text that indicates an intention to alter the normal
adjudicative process for weighing evidence and evaluating it against the burden of
10
persuasion. The only thing that Section 17.2 says about the taxpayer’s evidence is that
“the taxpayer may introduce evidence to prove the correct assessment.” IND. CODE
§ 6-1.1-15-17.2. But that is just an affirmative grant of permission to the taxpayer to
offer proof of an alternative value. It is not a limitation on the use of evidence offered by
the assessor. Section 17.2 does not place any limitation on or provide any direction
about the Board’s use of the evidence presented by each party.
Examining the precise contours of an assessor’s burden of proof is instructive in
resolving the question presented here. Section 17.2 requires the assessor to prove that
the challenged “assessment is correct.” IND. CODE § 6-1.1-15-17.2. Under that text, a
determination by the Board that the assessor’s evidence does not satisfy the assessor’s
burden of proof is not a determination that the assessor’s evidence lacks all probative
force. It is only a determination that the evidence does not exactly and precisely prove
the accuracy of the assessment. See Southlake Indiana, LLC v. Lake Cnty. Assessor,
(“Southlake III”) 181 N.E.3d 484, 489 (Ind. Tax Ct. 2021) (holding that the word “correct”
in Section 17.2 requires that an appraisal “exactly and precisely conclude to” the
challenged assessment), trans. denied. Even when it does not exactly match the
assessment, an assessor’s evidence may still shed light on the true tax value of the
property. It may still persuasively demonstrate, for example, that the subject property
should be assessed at a higher or lower value than the challenged assessment, as was
the case here. (See Cert. Admin. R. at 3024–25 ¶ 90 & n.11.) In establishing the burden
of proof, Section 17.2 sets a high bar for the assessor, but it does not direct the Board
to ignore persuasive evidence of value offered by the assessor when evaluating the
taxpayer’s proposed assessment.
11
Nestlé insists that the Indiana Supreme Court’s decision in Southlake Indiana,
LLC v. Lake Cnty. Assessor, (“Southlake II”) unequivocally answers the question
presented and bars consideration of the Assessor’s appraisal. 174 N.E.3d 177, 180
(Ind. 2021). But Nestlé presses the Supreme Court’s holding too far. The holding of
Southlake II is a narrow one. There the Court held that, when the Board determines that
the parties’ evidence is “lacking” and thus “that neither party met its burden of proof,”
the assessment reverts to the assessment for the prior tax year. Southlake II, 174
N.E.3d at 179. As was the case in Southlake II, that means that the Board cannot
fashion its own assessment value by “[m]aking the adjustments it [finds] warranted” to
the parties’ evidence or appraisals. Id. The Supreme Court’s holding, therefore, only
resolves the question of whether the Board may assign a value other than the
reversionary value (i.e., the prior year assessment) when the Board finds that both
parties’ appraisals are insufficient to prove the value of the property. It says nothing
about whether evidence introduced by the party not having the burden of proof may be
brought to bear on the evaluation of whether the party having the burden of proof has
met that burden.
In its attempt to avoid the narrowness of the holding in Southlake II, Nestlé points
to a comment by the Supreme Court that the legislature is empowered to limit the
Board’s discretion in property tax appeals. Responding to this Court’s then-articulated
concern that restricting the Board’s ability to resolve conflicting evidence would be
problematic, the Supreme Court said:
12
In the tax court’s view, applying section 17.2’s plain language would mean
the state board could not resolve conflicting probative evidence, an
outcome the tax court viewed as improper: “To require the Indiana Board
to determine weight and credibility subject to the rigid and formulaic
approach advocated by Southlake (i.e., that it should have examined the
[assessor’s] appraisal on a ‘stand-alone’ basis) would actually remove the
Indiana Board’s ability to resolve any issues arising from conflicting
evidence.” Southlake, 160 N.E.3d at 1169–70. How the tax court
described the state board’s limited discretion may be correct. But that
result, whatever its policy merits, is the legislature’s call and not ours. We
apply the statute as written and do not second guess the legislature’s
decision to limit the state board’s flexibility when assessed values increase
by more than the five-percent threshold.
Southlake II, 174 N.E.3d at 179–80 (alteration in original). Nestlé asserts that this
statement establishes a rule requiring the Board to examine the Assessor’s appraisal on
a stand-alone basis.
Nestlé’s interpretation of this analysis is wrong. Contrary to Nestlé’s contention,
Southlake II expresses neither an endorsement nor a refutation of the Tax Court’s
concern. Instead, the opinion acknowledges that such a concern “may be correct” and
places the resolution of the concern with the legislature. Southlake II, 174 N.E.3d at 180
(emphasis added). The opinion provides no analysis of the statute that would support
the position advanced by Nestlé here. It provides context for the Supreme Court’s
important point about the separation of powers and the discretion of the legislature to
make policy determinations. 1
1
Nestlé also argues that this Court’s decision in Madison Cnty. Assessor v. Kohl’s Indiana, LP
bears on the analysis here. 272 N.E.3d 592, 600 (Ind. Tax Ct. 2025). Nestlé quotes the decision
for the principle that an appraisal must meet the preponderance standard “standing alone and
independent of the Assessor’s competing appraisal.” (Pet’r’s Br. at 8–9 (quoting Kohl’s, 272
N.E.3d at 600).) In Kohl’s, the Court found that the Board failed to perform the statutorily
required preponderance analysis when it found only that the Kohl’s appraisal valuation was
more likely the true tax value of the property than the Assessor’s appraisal valuation but did not
find that the Kohl’s valuation was more likely than not the value of the subject property. Id.
Accordingly, Nestlé reads the quote out of context. When read within the context of the holding
in Kohl’s, it is clear that the Court was distinguishing between a preponderance analysis and the
13
The statutory silence is dispositive, leaving the status quo undisturbed. The
legislature is presumed to know the prevailing law when it adopts new legislation and to
craft legislation with that background in mind. See Garrison v. Sevier, 165 N.E.3d 996,
999 n.1 (Ind. Ct. App. 2021); IBEW Loc. 305 v. Allen Cnty. Assessor, 278 N.E.3d 395,
403 (Ind. Tax Ct. 2026). Accordingly, absent language altering the background law, a
statute should be read in harmony with that law. The relevant background law here is
the law that governs the adjudicative process and the consideration of the parties’
evidence. “[I]t is a well-established principle of law that all relevant evidence
introduced in the trial court must be considered regardless who introduced it.” Ellis v.
Thompson, 8 N.E.2d 430, 432 (Ind. Ct. App. 1937) (en banc). For more than a century,
Indiana’s fact-finding courts and administrative bodies have operated according to the
principle that “[when] a fact in issue is established by competent relevant evidence, it
matters not which party introduced it, or what other purpose he had in view in offering
it.” Inland Steel Co. v. Ilko, 103 N.E. 7, 9 (Ind. 1913); cf. Mirant Sugar Creek, LLC v.
Indiana Dep’t of State Revenue, No. 71T10-0803-TA-18, 2010 WL 2400436 at *3 (Ind.
Tax Ct. June 16, 2010) (allowing testimony by the respondent’s agent to be offered by
the petitioner against the respondent). As Section 17.2 says nothing about the
application of these principles, the Court must conclude that the legislature did not alter
them and that they continue to apply under Section 17.2.
evaluation of two appraisals exclusively against each other without regard for the burden of
persuading the Board of the property’s true tax value. The Court’s references to an appraisal
“standing alone and independent” is not a disallowance of competing evidence, but instead a
requirement that the Board “determine (1) if the assessment is ‘more likely than not’ incorrect
and (2) what alternative value is ‘more likely than not’ the true tax value of the property.” Kohl’s,
272 N.E.3d at 600.
14
It is no surprise that Section 17.2 is silent on the question raised by Nestlé.
Barring consideration of contrary evidence from an adverse party would neuter the
adversarial process altogether and lead to conflicting findings of fact. Reviewing
evidence from both parties when acting as a fact-finder is axiomatic in an adversarial
system and a fundamental part of the truth-seeking function inherent in the adjudicative
process. Courts and adjudicative bodies like the Board are not in the habit of siloing
evidence based on the identity of the party offering the evidence. A party is therefore
free to make their adversary’s case by admitting key facts or by offering other evidence
proving their point; a defendant who admits the elements of the plaintiff’s case on the
stand has no one to blame but himself. Cf. Peak v. Campbell, 578 N.E.2d 360, 361 (Ind.
1991) (“If an element [of the case] is admitted by the defendant, then the plaintiff no
longer has the burden of proving the admitted element.”). Moreover, siloing evidence
risks conflicting findings of fact where the one party’s evidence demands an inference
while the second party’s evidence demands the directly opposite inference (e.g., Party
A’s evidence requires an inference of a $1M assessment and Party B’s evidence
requires an inference of a $500k assessment). These challenges are in direct tension
with the fundamental structure of the adjudicative process and undermine its very
purpose.
This is not to say that the legislature could not have prescribed how the Board
was to weigh the evidence by statute. As the Supreme Court aptly explained in
Southlake II, the Board is a creation of the legislature and subject to its mandates. The
legislature is, of course, free to exercise its legislative authority as it chooses.
Southlake II, 174 N.E.3d at 180. It could have, subject to applicable constitutional
15
limitations, crafted Section 17.2 to limit the Board to looking only at the evidence of the
party with the burden in reaching its judgment as to that burden. Yet the text is silent on
that issue, and this Court may not read such a limitation into the text where one does
not exist. See Universal Health Realty v. Fluty, 144 N.E.3d 857, 862 (Ind. Tax Ct. 2020)
(clear, unambiguous statutory language “may not be expanded or contracted” by the
courts).
B. Nestlé did not meet its burden of proof because it did not meet the
burden of persuasion.
Regardless of whether Section 17.2 allows the Board to consider the Assessor’s
appraisal in evaluating whether Nestlé met its burden to prove the correct assessment,
Nestlé did not carry its burden of proof.
As noted by the Supreme Court in Southlake II, the legislature used the phrase
“burden of proof” in Section 17.2 and not “burden of production.” Southlake II, 174
N.E.3d at 180. The burden of proof includes both a burden of production and a burden
of persuasion. Id. This requires a party to both (1) “introduce enough evidence on an
issue to have the issue decided by the fact-finder,” id. at 180 (quoting BLACK’S LAW
DICTIONARY (11th ed. 2019)), and (2) “convince the fact-finder to view the facts in a way
that favors that party,” Burden of persuasion, BLACK’S LAW DICTIONARY 244 (11th ed.
2019). The burden of persuasion in property tax appeals is defined by statute and
requires proof to the level of a preponderance. See IND. CODE § 6-1.1-15-4(j) (2018);
Madison Cnty. Assessor v. Kohl’s Indiana, LP, 272 N.E.3d 592, 600 (Ind. Tax Ct. 2025).
Applied here, the preponderance standard required Nestlé to prove that its proffered
value more likely than not represented the value of the subject property. See Kohl’s,
272 N.E.3d at 600.
16
In its final determination, the Board, as the finder of fact, found that Nestlé
satisfied the burden of production by presenting a minimally credible valuation but did
not satisfy its burden of persuasion. (Cert. Admin. R. at 3024–25 ¶¶ 90–91.) That
distinction is decisive. A party does not carry its burden of persuasion merely by offering
credible evidence; it must persuade the trier of fact that its proposed assessment value
is more likely than not correct. See Kohl’s, 272 N.E.3d at 600–01 (an appraisal’s
“analysis and conclusions of value must stand on their own . . . [and] convince the finder
of fact to the level of a preponderance”; conclusory assertions of credibility “are not
enough”). Weighing the evidence in the record, the Board found that the most
persuasive assessment value was proffered by the Assessor’s appraisal, but that this
value was different from the original assessment. (Cert. Admin. R. at 3024–25 ¶¶ 88–
90.) Persuaded that the valuation presented by the Assessor more likely than not
represented the value of the subject property, the Board concluded that Nestlé failed to
meet its burden of proving the correct assessment. (Cert. Admin. R. at 3024–25 ¶¶ 90–
92 & n.11, 3026 ¶ 94.)
Even if the Board had set aside the Assessor’s appraisal entirely, Nestlé’s
evidence would not require the Board to adopt Nestlé’s appraisal valuation, as the
Board’s findings repeatedly note the lack of persuasive value in Nestlé’s appraisal. In its
final determination, the Board found Nestlé’s sales comparison approach “minimally
credible” and the appraisal’s conclusions to be “sufficiently supported (albeit barely).”
(Cert. Admin. R. at 3001 ¶ 33.) It concluded that Nestlé’s reconciled value was
“supported by only one reliable approach, the sales-comparison approach” and that
“th[e] approach [was not] particularly persuasive given the data presented.” (Cert.
17
Admin. R. at 3024 ¶ 88.) The Board found that Nestlé’s appraiser did not develop an
independent land value, meaning his cost approach was incomplete. (Cert. Admin. R.
at 3022–23 ¶ 84.) Likewise, it found that Nestlé’s appraiser failed to adequately support
his five percent functional-obsolescence adjustment with objective evidence,
demonstrated a lack of understanding of the case study underlying his external
obsolescence adjustment, and omitted critical supporting data for these adjustments
from his work file. (Cert. Admin. R. at 3000–01 ¶ 31.) The Board noted that Nestlé’s
comparable sales were mostly much older than the subject property and that its
appraiser even concluded that all but one were inferior to Nestlé’s property. (Cert.
Admin. R. at 3001 ¶ 32.) The Board took issue with the appraiser’s large adjustments to
leased comparables without analyzing whether those properties were leased at market
rent, concluding that those adjustments were “suspect at best.” (Cert. Admin. R. at
3024 ¶ 86.) And, finally, the Board expressed skepticism with Nestlé’s choice not to
develop an income approach at all. (See Cert. Admin. R. at 3001 ¶ 33.)
A finding of credibility is not a finding of persuasiveness as evidenced by the
Board’s findings that both appraisers presented credible estimates of value. (See Cert.
Admin. R. at 3001 ¶ 33, 3016 ¶ 68.) The Board’s half-hearted determination that
Nestlé’s appraisal is “minimally credible” in no way requires a finding of persuasive
value; on the contrary, the deficiencies identified in the appraisal are enough, on their
own, to support the Board’s conclusion that Nestlé’s appraisal is unpersuasive. The
Board’s conclusion rests on findings the Board made about Nestlé’s appraisal on its
own terms, not in comparison with competing evidence. Because neither party carried
its burden of persuasion, as articulated in Section 17.2, for the 2019 through 2021
18
assessment years, the Board correctly reverted the assessment to the value the Board
determined for 2018. 2
C. The Assessor waived its structural-improvements exclusion
argument by failing to raise it before the Board.
The Assessor first contends that the burden-shifting provision of Section 17.2
should not have been applied to the 2019 to 2021 tax years because the assessment
was based on structural improvements that qualified for a statutory exception. He claims
that the increase in the 2019 assessment was attributable to the ASRS addition
completed in 2018 and that such an improvement prevents the burden from shifting
under Indiana Code § 6-1.1-15-17.2(c). 3 The application of the burden-shifting rule to
the Assessor in this case is consequential—if the Assessor were relieved of the
exactitude required by the burden of proof in Section 17.2, then the Assessor’s
appraisal might well have been accepted. The Court disagrees with the Assessor.
The Assessor waived this exception by failing to raise it before the Board.
Generally, the Tax Court is “bound by the evidence and issues raised at the
administrative level,” meaning that any issue not raised before the Board is waived and
“may not be considered by the Court.” Kosciusko Cnty. Assessor v. Dalton Corp.,
158 N.E.3d 1286, 1291 (Ind. Tax Ct. 2020) (citation omitted); IND. CODE § 33-26-6-3. At
2
Nestlé also claims that the Board exceeded its authority and made the Assessor’s argument
for it. The decisions Nestlé invokes condemn other, broader practices like the Board’s supplying
evidence, legal theory, or arguments that a party failed to provide. See CVS Corp. #2519-01 v.
Prince, 149 N.E.3d 323, 328 (Ind. Tax Ct. 2020); Long v. Wayne Twp. Assessor, 821 N.E.2d
466, 471 (Ind. Tax Ct. 2005). Here, the Board did none of this. It simply weighed evidence that
both parties placed in the record and discharged its duty, as trier of fact, to determine the
relevance and weight of that evidence. See IND. CODE § 6-1.1-15-4(p); 52 IND. ADMIN.
CODE 2-7-2(c) (2018).
3
An automated storage and retrieval system (ASRS) is a series of steel racks with a protective
covering that holds palletized products and uses automated cranes traveling along the racks to
store and retrieve pallets. (Cert. Admin. R. at 0233, 0498, 1504–05, 1540–41.)
19
the outset of the hearing, the administrative law judge invited argument on the burden of
proof, and the Assessor concurred that Nestlé bore the burden without asserting any
exception. (Cert. Admin. R. at 3032–33.) The Assessor acknowledged the same at oral
argument. (Oral Arg. at 59.) The Board was not obligated to construct, on its own
initiative, an exception the Assessor neither asserted nor supported. See CVS,
149 N.E.3d at 327.
D. The Assessor had an adequate opportunity to address the correct
application of the burden-shifting statute before the Board.
The Assessor also argues that it lacked notice and a fair opportunity to address
the applicatio