STATE TAX COMMISSION OF MISSOURI
|TEETERING ROCKS EXECUTIVE LINKS, INC., Complainant,||)
Appeal Nos. 19-30270 through
|Parcel/Locator Nos.: See table, below.|
|GAIL MCCANN BEATTY, ASSESSOR||)
|JACKSON COUNTY, MISSOURI||)|
DECISION AND ORDER
Teetering Rocks Executive Links, Inc., (Complainant) appealed the Jackson County Board of Equalization’s (BOE) decisions finding the true value in money (TVM) of the subject properties as of January 1, 2019, classified as residential property, was as shown in the table, below:
|Appeal No.||Parcel/locator No.||BOE Determination of TVM|
Complainant claimed overvaluation of the TVM of the subject properties. Complainant failed to appear at the evidentiary hearing and did not produce substantial and persuasive evidence to support its claim. The BOE’s decisions are affirmed.
FINDINGS OF FACT
The subject properties in these appeals constitute a golf course located at 1080 NW South Outer Road, Blue Springs, Jackson County, Missouri. The evidentiary hearing was scheduled for August 23, 2021, at 10:00 a.m. Respondent timely appeared at the evidentiary hearing through counsel Elizabeth Judy. Complainant did not appear. Complainant did not seek a continuance or otherwise communicate any intent to proceed with the appeals.
CONCLUSIONS OF LAW
The taxpayer bears the burden of proof and must show by a preponderance of the evidence that the property was overvalued. Westwood P’ship v. Gogarty, 103 S.W.3d 152, 161 (Mo. App. E.D. 2003). Complainant did not appear at the evidentiary hearing and produced no evidence to support the overvaluation claim. Complainant’s failure to appear and failure to present any evidence, particularly no substantial and persuasive evidence, necessarily means Complainant failed to meet Complainant’s burden of proof. Consequently, Complainant did not prove overvaluation of the subject properties as of January 1, 2019.
The BOE’s decisions are affirmed. The TVM and assessed values of the subject properties, classified as residential property, for 2019 and 2020, are as shown in the table, below:
|Appeal No.||Parcel/locator No.||TVM||Assessed Value|
Application for Review
A party may file with the STC an application for review of this decision within 30 days of the mailing date set forth in the certificate of service for this decision. The application “shall contain specific detailed grounds upon which it is claimed the decision is erroneous.” Section 138.432. The application must be in writing, and may be mailed to the State Tax Commission of Missouri, P.O. Box 146, Jefferson City, MO 65102-0146, or emailed to Legal@stc.mo.gov. A copy of the application must be sent to each person listed below in the certificate of service.
Failure to state specific facts or law upon which the application for review is based will result in summary denial. Section 138.432.
The Collector of Jackson County, and the collectors of all affected political subdivisions therein, shall continue to hold the disputed taxes pending the possible filing of an application for review, unless the disputed taxes have been disbursed pursuant to a court order under the provisions of section 139.031.
SO ORDERED August 27, 2021.
STATE TAX COMMISSION OF MISSOURI
Amy S. Westermann
Certificate of Service
I hereby certify that a copy of the foregoing has been electronically mailed and/or sent by U.S. mail on August 27, 2021, to: Complainant(s) and/or Counsel for Complainant(s), the County Assessor and/or Counsel for Respondent and County Collector.
 Complainants timely filed a complaint for review of assessment with the State Tax Commission (STC). The STC has authority to hear and decide Complainants’ appeal. Mo. Const. art. X, sec. 14; section 138.430.1, RSMo 2000.
 For over 150 years, Missouri law has recognized the self-evident proposition that “if there be no evidence sufficient in law to make a prima facie case on this issue, plaintiff cannot be entitled to recover.” Callahan v. Warne, 40 Mo. 131, 135 (Mo. 1867).
 Missouri operates on a two-year reassessment cycle for valuing real property. See Section 137.115.1. Absent new construction or improvements to a parcel of real property, the assessed value as of January 1 of the odd year remains the assessed value as of January 1 of the following even year. Id.