Charles and Helen Conroy Trustees v. Jake Zimmerman, Assessor, St. Louis County

October 8th, 2021











Appeal No. 19-10812

)      Parcel/Locator 28O430397
v. )
Respondent. )



 Charles and Helen Conroy, Trustees, (Complainants) appealed the St. Louis County Board of Equalization’s (BOE) decision finding that the true value in money (TVM) of the subject property on January 1, 2019, was $225,000.  Complainants claimed overvaluation.  The parties agreed to waive an oral evidentiary hearing and have the appeal decided upon the record of evidence and exhibits. Complainants did not submit any exhibits, and Respondent submitted Exhibit 1, the October 4, 2019, Findings and Notice of Decision of the BOE. The BOE’s decision is affirmed.[1]

Complainants Did Not Prove Overvaluation

   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).   Complainants produced no evidence to support the overvaluation claim.  Complainants’ failure to present any evidence necessarily means Complainants failed to meet Complainants’ burden of proof.[2]


The BOE’s decision is affirmed.   The TVM of the subject property on January 1, 2019, was $225,000.[3]

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  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.

Disputed Taxes

The Collector of St. Louis 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   October 8, 2021.



Laura Storck-Elam

Senior Hearing Officer

State Tax Commission


Certificate of Service

I hereby certify that a copy of the foregoing has been electronically mailed and/or sent by U.S. mail on   October 8, 2021, to: Complainant(s) and/or Counsel for Complainant(s), the County Assessor and/or Counsel for Respondent and County Collector.


Elaina Mejia

Legal Coordinator




[1] 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.

[2] 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).

[3]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.