Full Opinion

PETITIONER APPEARING PRO SE: ATTORNEY FOR RESPONDENT: ANDY YOUNG THEODORE E. ROKITA Wadsworth, IL ATTORNEY GENERAL OF INDIANA SHELBY M. STOUDER FILED ATTORNEY FOR INTERVENOR: BENJAMIN M.L. JONES Aug 19 2026, 2:54 pm ROBERT B. GOLDING JR. DEPUTY ATTORNEYS GENERAL CLERK AMBER, GOLDING & HOFSTETTER Indianapolis, IN Indiana Supreme Court Court of Appeals Dyer, IN and Tax Court IN THE INDIANA TAX COURT ANDY YOUNG, ) ) Petitioner, ) ) and ) ) DEBORAH FOSTER, ) ) Intervenor, ) Case No. 25T-TA-00006 ) v. ) ) INDIANA DEPARTMENT OF LOCAL ) GOVERNMENT FINANCE, ) ) Respondent. ) ON APPEAL FROM A FINAL DETERMINATION OF THE INDIANA DEPARTMENT OF LOCAL GOVERNMENT FINANCE FOR PUBLICATION August 19, 2026 MCADAM, J. Indiana law allows taxpayers to challenge property tax valuations from multiple angles. A property owner is free, of course, to appeal a tax assessment on their specific parcel for a specific tax year. But there is another option, broader in its scope and prospective in its application. By statute, a taxpayer may petition the Department of Local Government Finance (“DLGF”) to review the schedule of land values (known as a “land order”) adopted by the county assessor that are used as part of the property assessment process. This latter approach was used by Young to challenge the land order adopted by the Lake County Assessor in 2023. However, Young, along with several members of the community, was unable to convince the DLGF that these base rates should be modified or rejected. Now, on appeal with this Court, Young and the Intervenor Foster raise a litany of issues to suggest that the DLGF’s review was insufficient. The Court does not agree, finding insufficient evidence in the record to overturn the DLGF’s final determination. FACTS AND PROCEDURAL HISTORY As noted in the introduction, this case is about a county land order. By statute, every county assessor is required to “determine the values of all classes of commercial, industrial, and residential land . . . in the county using guidelines determined by the department of local government finance.” IND. CODE § 6-1.1-4-13.6(a) (2025). A land order is the colloquial term for a document that contains those land values. See Young v. Dep’t of Loc. Gov’t Fin., 237 N.E.3d 1175, 1176 n.1 (Ind. Tax Ct. 2024), transfer denied, 255 N.E.3d 438 (Ind. 2025) (Young I). To determine the land values, the Assessor categorizes all property in a county into different neighborhoods (each of which is assigned a class based on majority use) and then selects representative sales disclosures or valuations that fairly represent the value of property in each neighborhood. See REAL PROPERTY ASSESSMENT GUIDELINES FOR 2021, Ch. 2 at 6–8 [hereinafter “GUIDELINES”] (incorporated by reference at 50 IND. ADMIN. CODE 2.4-1-2(c) 2 (2025)). By listing land values in the land order on a per-unit basis (e.g., per square foot, per front foot, etc.), the assessor effectively sets a “base rate” for a “base lot” in each neighborhood. Id. at 8 (noting that the base rate is the value of the “base lot” and “represent[s] the typical and average characteristics of lots in the neighborhood for the purpose of making pricing adjustments”). To determine the value of a specific parcel of land as part of an assessment, an assessor adjusts the base rate for that neighborhood with an influence factor, which “represents the composite effect that influences the value of certain lots within the boundaries of an entire neighborhood.” Id. at 43. This land value is then combined with the values of a property’s improvements and other rights that add or remove value to reach an assessment of the real property in question. GUIDELINES, Ch. 1 at 2 (explaining what is included in the reassessment of real property). By statute, a person may file a petition to have the DLGF review the land values determined in a land order. IND. CODE § 6-1.1-4-13.6(d). The petition must be filed not later than forty-five days after the land values are determined and must be signed by 100 property owners or 5% of the property owners in the county, whichever is fewer. Id. Once a valid petition is filed, the DLGF is required to “review the land values determined by the county assessor” and hold a public hearing. IND. CODE § 6-1.1-4-13.6(e). The DLGF must then approve, modify, or disapprove the land values. Id. In this case, the Lake County Assessor developed a new land order in 2023 and presented it to the Lake County Property Tax Assessment Board of Appeals (“PTABOA”) at a public meeting in June of 2023. The 2023 land order was created using sales data from 2021 and 2022 and replaced the land order developed in 2022. 3 Young challenged the Lake County Assessor’s 2023 land order using the petition process outlined in statute. He submitted a petition for review to the DLGF that included signatures from 170 affected property owners. After the petition was received, the DLGF notified the township and county assessors in Lake County and requested a copy of the land order, sales data used to create the land order, and information about the delineation of neighborhoods. In response to these requests, the assessors provided more than 2,800 pages of information on the 2023 Lake County land order, including the entire order itself, neighborhood counts, sales data, parcel lists, emails, and PTABOA meeting minutes. The DLGF scheduled a public hearing for October 10, 2023, and sent notice of that hearing, by mail, to each petition signatory approximately forty days before the hearing. In its notice, the DLGF included a hearing agenda, guidance for providing information, and instructions for registering to speak. The DLGF posted the hearing notice and exhibits on its website approximately one month before the hearing. Notice of the hearing was also posted outside of the Lake County Assessor’s office and outside the DLGF hearing room in Indianapolis. At the hearing, the DLGF received public comments from several property owners expressing concern about the 2023 land order, particularly from residents of the Miller Beach area in Calumet Township. These comments were not given under oath, and each speaker was limited to five minutes. The DLGF also received written comments from over 200 taxpayers both before and after the hearing. The DLGF also conducted two separate reviews of the data the Lake County Assessor used to create the 2023 land order. The reviews were completed by DLGF 4 field representatives at the request of the DLGF’s Director of Assessment. They analyzed underlying sales data from 2021 and 2022, reviewed ratio studies for each township, and performed focused analysis of Calumet Township and the Miller Beach area. 1 The DLGF issued its final determination on February 28, 2025 and ordered no change to the 2023 land order. In its determination, the DLGF noted that it reviewed the public comments, statistical tools used to create the land order, and the reports created by DLGF employees analyzing the land order sales data. The DLGF also explained that special attention was paid to the Miller Beach neighborhood, and Calumet Township more generally, because the taxpayers who expressed concerns about the land order were from those areas. When the ratio studies for these areas were reviewed, the DLGF found all data to be in the proper range and in compliance with assessment and appraisal standards. Ultimately, the DLGF concluded that (1) the 2023 land order was properly prepared, (2) the base rates were determined using correct methodologies and sufficient data, and (3) taxpayers submitted no probative evidence warranting modification or disapproval. (Cert. Admin. R. at 4051, 4054.) Young then appealed the DLGF’s determination to this Court. Foster later moved to intervene in the appeal, which the Court granted after neither party opposed her request. 1 A ratio study compares the assessed values of properties within a jurisdiction by using objective, verifiable data, such as sales prices or appraisals. Thorsness v. Porter Cnty. Assessor, 3 N.E.3d 49, 51 (Ind. Tax Ct. 2014). 5 STANDARD OF REVIEW The party challenging the DLGF’s final determination bears the burden of demonstrating its invalidity. City of Greenfield v. Indiana Dep’t of Loc. Gov’t Fin., 22 N.E.3d 887, 891 (Ind. Tax Ct. 2014). This Court reviews “the propriety of 1) the DLGF’s factual findings and 2) the DLGF’s legal conclusions in light of those factual findings.” Indianapolis Pub. Transp. Corp. v. Indiana Dep’t of Loc. Gov’t Fin., 988 N.E.2d 1274, 1277 (Ind. Tax Ct. 2013) (citing State Bd. of Tax Comm’rs v. Gatling Gun Club, Inc., 420 N.E.2d 1324, 1326–29 (Ind. Ct. App. 1981)). Accordingly, a petitioner must demonstrate that the final determination is arbitrary and capricious, an abuse of discretion, contrary to law, or unsupported by substantial evidence. City of Carmel v. Indiana Dep’t of Loc. Gov’t Fin., 246 N.E.3d 832, 834 (Ind. Tax Ct. 2024), review denied sub nom. City of Carmel v. Dep’t of Loc. Gov’t Fin., 259 N.E.3d 998 (Ind. 2025). The Court neither reweighs the evidence nor judges the credibility of witnesses in its review. Brown v. Dep’t of Loc. Gov’t Fin., 989 N.E.2d 386, 390 (Ind. Tax Ct. 2013). DISCUSSION The Petitioner and Intervenor each raise multiple challenges to the DLGF’s determination affirming the Lake County land order for 2023. While both believe that the DLGF failed to adequately review the land order, their arguments differ substantially and merit separate discussion. Therefore, to ensure the Court is both thorough and efficient in its examination of every argument presented, the claims of Young and Foster will be discussed separately. 6 I. Young’s Claims Young raises numerous claims in this appeal, many of which overlap or are not clearly delineated. Although Young bears the burden of demonstrating prejudicial error by the DLGF in this case, the Court has categorized his claims to ensure thorough analysis. A. Timing of the 2023 Land Order Young asserts two claims of error related to the timing of the 2023 land order. First, Young claims that the land order was submitted too late to apply to the 2023 assessment year. He contends that, because the Assessor did not present the 2023 land order to the PTABOA until June 21, 2023—after the January 1, 2023 assessment date under Indiana Code § 6-1.1-2-1.5(a)(2)—the land values contained therein could not lawfully be applied to 2023 payable 2024 tax bills. 2 (Pet’r Br. at 5, 8–9, 13–14.) Second, Young argues that the 2023 land order impermissibly overlaps with the 2022 land order, which this Court addressed in a previous case, Young I, involving the same petitioner. (Pet’r Br. at 5, 15.) Young believes that Young I established a requirement that the 2022 land order be applied to the 2023 tax year. See id. The Court disagrees with Young on both claims. Regarding Young’s claim that the 2023 land order was submitted too late, Young conflates the annual assessment date for valuing tangible property under Indiana Code § 6-1.1-2-1.5 with the process for the preparation and submission of land orders. The deadline for preparing and submitting land orders is established by a county’s 2 For clarity, property taxes are often referenced by both assessment and payment years because, absent an exception, property taxes “assessed for [one] year . . . are due . . . the following year.” IND. CODE § 6-1.1-22-9(a). 7 reassessment plan. Indiana Code § 6-1.1-4-13.6(a) expressly requires an assessor to submit a land order to the PTABOA and DLGF “by the dates specified in the county’s reassessment plan.” By contrast, the annual assessment date is the point in time at which the value of property is determined for purposes of property taxation. See IND. CODE § 6-1.1-1-2 (defining the “assessment date” as “the date on which tangible property is assessed and valued for purposes of collecting ad valorem property taxes imposed for that date”); IND. CODE § 6-1.1-2-1.5. The annual assessment date is not a deadline by which assessors must complete land orders. This Court previously rejected this argument that a land order submitted to the PTABOA after the January 1 assessment date was untimely in Camelot Co., LLC v. Bartholomew Cnty. Assessor, 224 N.E.3d 1007, 1014 (Ind. Tax Ct. 2023). There, the Court explained that Indiana law does not prohibit an assessor from using valuation data submitted to the PTABOA after the assessment date: [W]hile Indiana’s annual assessment date is January 1 . . . that does not mean that assessments are actually completed and finalized on that date. For example, when formulating land values to be used in a given assessment year, assessing officials are to analyze and rely on data from sales transactions that have occurred through and including December 31 of the previous . . . calendar year . . . . [I]t is not possible for assessing officials to analyze all applicable sales data, determine land values, submit them to the [PTABOA], reassess overall assessment valuations using those land values, update corresponding record cards, and provide notice to taxpayers of changes to assessments between December 31 and January 2. Accordingly, . . . the process by which land values and land orders are determined and applied must be very fluid and flexible. Indiana’s Assessment Manual provides that flexibility by specifying that property assessments are to reflect a valuation “as of” the January 1st date. Id. at 1015 n.5 (internal quotation marks, citations, and emphasis omitted); see also Marion Cnty. Assessor v. Simon DeBartolo Grp., LP, 52 N.E.3d 65, 69–70 (Ind. Tax Ct. 8 2016) (recognizing that evidence of value from dates after an assessment date may be used to value a property if there is “[an] attempt to relate that evidence to the appropriate valuation and assessment dates”). In this case, there is no evidence that the 2023 land order was not adopted by the deadline established in Lake County’s reassessment plan. The 2023 land order was completed within the first year of the reassessment cycle, and its base rates appear to apply prospectively from the time of its submission. (Cert. Admin. R. at 3311–3312, 3932 (showing the 2023 land order was submitted to PTABOA on July 12, 2023).) As in Camelot, no Indiana law prohibited the Lake County Assessor from submitting the 2023 land order when she did. 3 As to the purported overlap with the 2022 land order that Young raises in his second claim, Young misreads this Court’s decision in Young I. Young points to this Court’s observation that: [B]ase rates in [the 2022 land order] will be applied to taxes due in 2023 and subsequent years until the year after the next determination of land values is adopted. The next land values determination must be adopted no later than 2026, though it may be prepared at any time within the reassessment cycle. Young I, 237 N.E.3d at 1178. According to Young, the Court’s statement that the 2022 land order “will be applied to taxes due in 2023” is binding and precludes the Assessor 3 Although not addressed by any party, it appears that the Assessor’s application of the land order to assessments is consistent with statute. Indiana Code § 6-1.1-4-4.2 provides that “[a] reassessment is the basis for taxes payable in the year following the year in which the reassessment is to be completed.” IND. CODE § 6-1.1-4-4.2(a)(7) (2023) (emphasis added). Here, the Assessor submitted the land order in 2023 and applied the new values to 2023 assessments which would have been the basis for taxes payable in 2024. (Cert. Admin. R. at 3302, 3311–12 (documenting the Assessor’s submission of the land order to the PTABOA in June 2023); Cert. Admin. R. at 3932 (noting that “new land base rates were implemented for the January 1, 2023 assessment date”).) 9 from adopting a new land order for that year. But Young reads too much into the Court’s attempt to contextualize its holding. The Court went on to explain that a new land values determination “may be prepared at any time within the reassessment cycle.” Id. Young I simply clarified the relationship between the four-year reassessment cycle and the timing of land orders, explaining that “[t]he four-year period is not the time during which a particular determination of land values applies. Rather, it is the period during which at least one land values determination must be adopted.” Id. at 1177. As Young I explains, Indiana Code § 6-1.1-4-4.2 only requires that “each group of parcels shall be reassessed under the county’s reassessment plan once during each four (4) year cycle.” IND. CODE § 6-1.1-4-4.2. This occurred here. Although the DLGF does not make such a finding in its final determination, the record establishes that the 2022 and 2023 land orders were issued during different assessment cycles. As part of its review of Young’s petition, the DLGF noted that: The county’s 2023 land order was part of the current four (4) year cyclical plan. This land order was done and was implemented in the first year of the 4 year cycle. The new land base rates were implemented for the January 1, 2023 assessment date. (Cert. Admin. R. at 3932.) Consistent with this fact, the 2022 land order was issued in the last year of its assessment cycle. See Young I, 237 N.E.3d at 1178 (“The Lake County Assessor submitted a new determination of land values at the Lake County PTABOA meeting on April 6, 2022, again in the last year of that four-year cycle.” (emphasis added)). The 2023 land order, then, was issued in the first year of its own four-year cycle. (Cert. Admin. R. at 3932.) This evidence shows compliance with Indiana Code § 6-1.1-4-4.2, and Young does not otherwise support his claim that the 2023 land order, which could be “prepared at any time within the reassessment cycle” 10 prior to 2026, improperly overlapped with the previous land order. Young I, 237 N.E.3d at 1178. Accordingly, the DLGF did not err in concluding that the 2023 land order was timely. 4 B. Sufficiency of Sales Data Young contends that the 2023 land order was based on insufficient sales data, pointing to notes in the portion of the land order regarding Calumet Township which he claims indicate that many neighborhoods had no vacant land sales or that the only available sales were tax sales. (Pet’r Br. at 6, 10, 16–17; Cert. Admin. R. at 847–862.) Young argues that the near total absence of normal market sales of vacant land indicates a “moribund market” and that large base rate increases over the prior year were unjustified. (Pet’r Br. at 17.) The Court finds that Young has failed to demonstrate that the available market data was insufficient to support the values in the land order. The DLGF’s regulations expressly contemplate alternative methods for valuing land when sales are limited. The DLGF’s administrative rule, 50 Indiana Administrative Code 27-5-7, provides that “[t]he sales comparison approach is the primary approach to land valuation and is always preferred when sufficient sales are available.” 50 IND. ADMIN. CODE 27-5-7(b) (2025). However, when fewer than five sales exist in a given stratum, the rule 4 It is not obvious whether the DLGF may review the components of the land order plan creation process; Indiana Code § 6-1.1-4-13.6 only explicitly authorizes the DLGF to (1) review the land values and (2) approve, modify, or disapprove those values. Questions regarding the frequency of land reassessments in a land order plan, the effective date of a land order, or the propriety of adopting of multiple land orders within a 4-year cycle may require review through a different mechanism or may even be properly reviewed by a different entity, such as the Indiana Board of Tax Review. However, such questions will be left for another day, as they are neither raised by the parties nor necessary to resolve this appeal. 11 authorizes several alternative methods, including using land values from a similar neighborhood, extracting land value from valid sales of improved properties, or expanding the time period from which sales are drawn. Id. at (b)(1)–(3). The record reflects that the DLGF’s field representatives carefully analyzed the sales data underlying the 2023 land order and found sufficient sales of improved properties to extract a land value as permitted by the DLGF’s regulations. (Cert. Admin. R. at 4058–4061.) For Calumet Township, the DLGF found 1,337 valid sales for residentially improved property. The ratio study statistics showed that the median assessment ratio, coefficient of dispersion, and price-related differential were within the standard of the International Association of Assessing Officers (“IAAO”). 5 The DLGF further analyzed individual Miller Beach neighborhoods and confirmed that each met the applicable statistical parameters. Young does not identify legal, mathematical, or other authoritative support to establish a minimum threshold of sales data beyond that expressed in 50 Indiana Administrative Code 27-5-7. Likewise, while Young believes that the sales data was misinterpreted and led to base rate changes that are “mathematically impossible,” he provides no support for these claims. He does not provide a competing analysis of the data or point to any authority to support his claims that the methodology employed by the DLGF and Assessor was improper. Without legal support, Young’s assertions are conclusory and cannot be used by this Court to overturn the DLGF’s determination. 5 The IAAO is an educational and research association of individuals working with property taxation and assessments. See Meridian Towers E. & W. v. Washington Twp. Assessor, 805 N.E.2d 475, 480 n.8 (Ind. Tax Ct. 2003). IAAO standards are expressly permitted by law for use by county assessors and the DLGF in adjustments and equalizations. 50 IND. ADMIN. CODE 27-1-4. 12 See, e.g., Marinov v. Tippecanoe Cnty. Assessor, 119 N.E.3d 1152, 1156 (Ind. Tax Ct. 2019) (noting generalized statements without supporting evidence are merely conclusory and are not sufficient to overturn an assessment). Because Young failed to show that the DLGF’s examination of the sales data was inadequate, the Court will not disturb the DLGF’s final determination on this ground. C. Valuation Methodology Young challenges the Assessor’s use of the abstraction and allocation methods to determine land values, arguing that the Assessor over-relied on these methods and that they yielded arbitrary results. 6 (Pet’r Br. at 6, 17–18.) Young also argues that the Assessor should have relied more heavily on tax sales when analyzing sales data. (Pet’r Br. at 18.) This criticism of the Assessor’s methodology, however, is not accompanied by legal or factual support to show the Court that an error has occurred. Without such support, Young’s claims cannot demonstrate the errors he alleges. As such, the Court declines the invitation to overturn the DLGF’s determination on this basis. The abstraction and allocation methods for valuing residential land are authorized by Indiana law. The DLGF’s Real Property Assessment Guidelines explain that “[w]hen establishing land values throughout the jurisdiction, each assessing official shall evaluate sales information by using the sales comparison method, the abstraction method, or the allocation method.” GUIDELINES, Ch. 2 at 12 (emphasis added). The abstraction method estimates land value by subtracting the depreciated value of 6 Young occasionally refers to the “extraction method” and the use of a “15–20% land to value” ratio. (See, e.g., Pet’r Br. at 17.) The Court understands him to mean the abstraction method and a land-to-improvement ratio. 13 improvements from the sales price. Id. The allocation method estimates land value by analyzing the percentage contribution of land to the total sale. Id. at 13. Both methods value land by obtaining sales data for improved properties and deriving a land value by removing the value of improvements—a practice which is explicitly authorized by Indiana law when unimproved sales are insufficient. See 50 IND. ADMIN. CODE 27-5-7(b)(2) (permitting assessors to “[e]xtract the land value from valid sales of improved properties” when there are insufficient sales available in a stratum). The Assessor’s application of the abstraction and allocation methods was reviewed by the DLGF when it had two different experts review the content of the submitted ratio studies used to determine the land values; both found that the methods complied with all IAAO requirements. (See Cert. Admin. R. at 3934–35, 3938–40.) Without any analysis showing how or why the Assessor’s calculations or methodology were flawed, the Court is left with a bare supposition, which cannot meet Young’s burden on appeal. Young’s other contention that tax sales should have played a larger role in the creation of the land order is wholly unsupported. Tax sales occur when property is sold to satisfy tax debt and are not necessarily reflective of a property’s market value-in-use. See Robey v. Fairfield Twp. Assessor, No. 49T10-0708-TA-42, 2009 WL 4668740, at *5 (Ind. Tax Ct. Dec. 9, 2009); cf. INTERNATIONAL ASSOCIATION OF ASSESSING OFFICERS, STANDARD ON RATIO STUDIES at 49 (Apr. 2013) (noting that forced sales are generally invalid for ratio studies without evidence that the sale was an open market transaction), https://www.iaao.org/wp-content/uploads/Standard_on_Ratio_Studies.pdf. Nonetheless, Young asserts that the high frequency of tax sales demonstrates a downward trend in 14 the area’s real estate market. While this may very well be true, Young fails to support his claim with data, calculations, legal citations, or expert testimony. Beyond his unsupported claim, there is no authority provided for the proposition that assessors should incorporate tax sale data into their land order analysis. As this Court held in Robey, use of a tax sale to value a property requires a demonstration “that the bid price is probative [of] the property’s market value-in-use.” Robey, No. 49T10-0708-TA-42, at *5. Young has therefore failed to demonstrate a reason to overturn the DLGF’s determination on this basis. D. Pricing Methods Young takes issue with the Assessor’s decision to use the per-square-foot (“PSF”) method rather than the per-front-foot (“PFF”) method to value residential land in the Miller area. (Pet’r Br. at 19–20.) He asserts that the Lake County and Calumet Township assessors have been using the PSF method to assess residential land in Lake County. (Pet’r Br. at 20.) He argues that, because the 2023 land order did not include PSF pricing for residential vacant land in Miller, the entire land order should be “set aside” and that any assessments of residential land utilizing the PSF method should be deemed invalid because they are not in compliance with the 2023 land order. (Pet’r Br. at 20.) The Court finds that the lack of such a pricing method does not undermine the land order or require a remand. First, to the extent that Young is challenging the application of the land values in the 2023 land order to the assessments of specific properties, such a claim is outside the scope of the review contemplated by Indiana Code § 6-1.1-4-13.6(e). The DLGF’s review of the 2023 land order concerned the base rates applicable to classes of land 15 across the county, not the application of those rates to individual parcels. See IND. CODE § 6-1.1-4-13.6(a) (when creating a land order, “[t]he county assessor shall determine the values of all classes of . . . residential land . . . [and] submit the values and any supporting document to the county”). The sole power granted to the DLGF by the statute is to “review the land values determined by the county assessor” and “approve”, “modify”, or “disapprove” those values. See IND. CODE § 6-1.1-4-13.6(e) Whether a particular land value determined in a land order is properly applied to a particular parcel is beyond the scope of the DLGF’s power under section 6-1.1-4-13.6. Such claims are a different matter with a different process, appropriately channeled through the property tax appeal process. See IND. CODE § 6-1.1-15-1.1, -1.2 (identifying the available claims, applicable deadlines, and initial review processes for appealing assessments of tangible property owned by individual taxpayers.) Second, to the extent Young is correct that the 2023 land order did not include PSF pricing for residential land, the DLGF’s assessment rules give assessors wide latitude to decide which particular pricing method to use and note that many different pricing methods are valid. The Real Property Assessment Guidelines describe five types of unit values for land valuation: front foot value, square foot value, acreage value, site value, and unit density. GUIDELINES, Ch. 2 at 13–15. The Guidelines specifically note that “[i]t should be stressed that the pricing method for valuing the neighborhood is of less importance than arriving at the correct value of the land as of the valuation date.” Id. at 14. The Guidelines also provide that the assessing official determines which unit value is appropriate and advise that the determination of which pricing method is appropriate turns on several factors. Id. at 13–14 (listing the following factors: “size, 16 dimensional data available on tax maps or plat maps, methods of comparison used by the typical buyer and seller, and the ease of application”). Here, the DLGF, in its review, determined that the methods used by the Assessor were correctly applied and Young has not provided any authority to support his claim that they were not. E. Statutory Notice Requirements for the DLGF’s Hearing Young argues that the DLGF’s notice of the public hearing was inadequate and did not comply with Indiana Code § 5-3-1-2. (Pet’r Br. at 7, 27.) Young contends that public notice of the DLGF’s hearing and the Assessor’s land order should have been included in the local newspapers. The Court concludes that no such requirement exists and that the notice provided by the DLGF was sufficient. Young fails to demonstrate that the DLGF’s hearing was subject to Indiana Code § 5-3-1-2. Subsection a of Indiana Code § 5-3-1-2 limits the application of the statute’s notice requirement to situations “when notice of an event is required to be given by publication in accordance with this chapter.” IND. CODE § 5-3-1-2(a). Young has not provided any analysis or pointed to any authority linking section 5-3-1-2 to the DLGF’s review under section 6-1.1-4-13.6; the Court will not endeavor to do so on its own. It is the litigant’s responsibility to walk the Court through its argument and explain its contention. Ciceu v. Knox Cnty. Assessor, 272 N.E.3d 583, 589 n.4 (Ind. Tax Ct. 2025). The applicable law in this instance, as was the case in Young I, does not impose a statutory notice requirement on the DLGF beyond the obligation to hold a public hearing. IND. CODE § 6-1.1-4-13.6. 7 “The Indiana General Assembly has provided 7 The legislature recently amended Section 13.6 to add a requirement that “notice of the hearing shall be given by the [DLGF] to the assessor and to the first ten (10) petitioners at least five (5) days before the date of the hearing.” IND. CODE § 6-1.1-4-13.6 (2026); see Pub. L. No. 230-2025, § 20, 2025 Ind. Acts 3719. This provision did not exist when the DLGF held its 17 specific public hearing notice requirements in multiple places throughout Indiana Code’s Article 6-1.1, and here it has not done so.” Young I, 237 N.E.3d at 1181. As this Court said in Young I, “the Court will not create its own specific notice requirement. That is a matter for the legislature.” Id. Even so, like the facts in Young I, the record here demonstrates that the DLGF made reasonable efforts to provide public notice. The DLGF scheduled the hearing for the evening after traditional working hours and allotted each taxpayer who requested to speak up to five minutes of time to testify. The DLGF mailed individual letters to all 171 petition signatories that included “a hearing agenda, guidance for providing evidence, and instructions for registering to speak at the hearing” along with a “virtual computer link address for members of the public to electronically attend the hearing” and a phone number for taxpayers to participate by telephone. (Cert. Admin. R. at 4051.) The DLGF posted the hearing notice and exhibits on its website approximately one month before the hearing, and the Assessor posted notice outside her office. (Cert. Admin. R. at 3929–3930, 4051–4052.) The DLGF also accepted written submissions for two weeks after the hearing and responded to communications with over 250 individual taxpayers. Nothing further was required of the DLGF. F. DLGF Review of Individual Taxpayer Properties Young objects to the DLGF’s thorough review of properties he owns, asserting that DLGF staff spent “an inordinate amount of time” investigating his holdings and that this was irrelevant to the land order review. (Pet’r Br. at 23–25.) The record reflects that the DLGF reviewed properties belonging to Young and other petition signatories to hearing and so does not apply in this case, though the Board’s actions far exceed the new statutory requirement for notice. 18 cross-check its analysis of the 2023 land order. (Cert. Admin. R. at 4059.) Young does not explain how the DLGF’s consideration of this information rendered the 2023 land order flawed or the final determination erroneous. If anything, the DLGF here exercised reasonable judgment, focusing its review efforts on the property owners who were likely affected the most, as such an effect would motivate action in those owners. The mere fact that the DLGF examined the petitioner’s properties as part of its review does not establish that the review was biased or improper. G. Assessment Errors Young also points out a specific instance where he believes the DLGF failed to make proper adjustments to an erroneous property valuation. He specifically references a property in Gary that sold for over $7 million in 2022 but was assessed at $7,400. (Pet’r Br. at 25 n.19.) Young says that although this issue was brought to the DLGF’s attention, the property value was not changed. But, again, Young overstates the scope of the DLGF’s review. A review of a land order looks for correct values of land categories, not the accuracy of individual property assessments. See IND. CODE § 6-1.1-4-13.6(e) (directing DLGF to “review the land values determined by the county assessor” and “approve”, “modify”, or “disapprove” them). Such individualized review is a different matter with a different process, appropriately channeled through the property tax appeal process. See IND. CODE § 6- 1.1-15-1.1, -1.2 (identifying the available claims, applicable deadlines, and initial review processes for appealing assessments of tangible property owned by individual taxpayers.) As such, Young’s claim is beyond the scope of the statutory review process underlying this appeal. 19 H. Other Assertions Beyond the arguments outlined in detail above, Young also makes a multitude of assertions without support from legal or evidentiary citations. These assertions include that such high magnitude base rate increases are impossible, that the base rate for U.S. Steel’s land demonstrates unequal treatment, that the Assessor misinterpreted sales data, and that specific errors exist in land order entries or their applications to specific properties. (Pet’r Br. at 4–5, 9, 21–23, 25–26; Pet’r Suppl. Br. at 2–3, 6–7; Pet’r Suppl. Reply Br. at 2–4.) In some instances, the assertions are particularly severe, such as where Young alleges that the Lake County Assessor and the DLGF “perpetrated a fraud” and relied on “fraudulent data” for its studies. (Pet’r Br. at 4–5.) It is not always clear what remedy Young is requesting or believes to be appropriate. 8 Pro se litigants are held to the same legal standards as licensed attorneys; they cannot avoid this Court’s standard of review or plead ignorance of its requirements. Ciceu, 272 N.E.3d at 588. Among those standards is the requirement to explain the legal and factual basis of each claim and walk the court through the analysis. Id. at 589 n.4. Because Young has not done that here with any of these claims, the Court considers them waived and will not address them further. Id. 9 8 Young’s Supplemental Brief suggests that the Court should order the DLGF to review all value increases over 100%. (Pet’r Suppl. Br. at 1 (“It would be a gross injustice to let the base rates that increased by 3 and 4-digit percentage[s] . . . stand”).) Such a claim was untimely presented in the post-hearing supplemental briefing and could have been addressed in Young’s initial brief. It was also unauthorized by the Court’s limited order for supplemental briefing. The argument is therefore waived. Davidson v. State, 211 N.E.3d 9