Transform, Ltd. v. Polk County

This appeal concerns the proper application of the statutory two-year valuation cycle that governs the state's system of property tax assessment. Under this system, real property is independently valued only in odd-numbered ""assessment"" years. In the even-numbered, or ""interim"" years, the assessment — absent error or change in value — is ""locked into"" the valuation from the preceding year. Vogt v. Board of Review, 519 N.W.2d 395, 396 (Iowa 1994). The question is whether a taxpayer who successfully challenges an odd-numbered year assessment is entitled to a comparable adjustment to the interim-year assessment in the absence of a timely protest or appeal. Because we believe, as did the district court, that the taxpayer is entitled to the benefit of the reduction in both years, we affirm the judgment for the plaintiff.