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IN THE OREGON TAX COURT
MAGISTRATE DIVISION
Property Tax

ARMSTRONG WORLD INDUSTRIES,

  
) ) ) ) ) ) ) ) )
)
)
  
  

  Plaintiff,
  
  
TC-MD 100671B


v.

COLUMBIA COUNTY ASSESSOR
and DEPARTMENT OF REVENUE,
State of Oregon,

  
  
  
DECISION

  Defendants.
  
  



Plaintiff appeals the real market value of industrial property improvements identified as Account 13220 (subject property) for the 2009-10 tax year.  A trial was held in the Tax Courtroom, Salem, Oregon on August 8, 2011.  Andrew Hall (Hall), Property Tax Director, Ryan, Inc., appeared and testified on behalf of Plaintiff.  Joseph A. Laronge, Senior Assistant Attorney General, appeared on behalf of Defendant Department of Revenue (Department).  Rob Motley (Motley), Senior Industrial Appraiser, and Don Brutke (Brutke), Principal Industrial Appraiser, both testified on behalf of the Department.  Defendant Columbia County Assessor did not appear at trial because the land value is not at issue in this matter.  
Plaintiff.s Exhibit 1 was offered and received over the Department.s objection.  The Department objected to the admission of those parts of Plaintiff.s Exhibit not supported by expert witness testimony.  The court admitted Plaintiff.s Exhibit 1, noting that the Department.s objection would be considered in weighing the evidence.  The Department.s Exhibits A, B, and Rebuttal Exhibit D were received without objection.  Plaintiff objected to the Department.s Rebuttal Exhibit C because that document was prepared by Plaintiff during 2008, but the date of preparation is unknown; the Department.s Rebuttal Exhibit C includes figures from 2006, 2007,
and estimates for 2008.  The court admitted the Department.s Rebuttal Exhibit C over Plaintiff.s objection, noting that the objection would be considered in weighing the evidence.
I.  STATEMENT OF FACTS
Motley testified that the subject property, which is located in St. Helens, Oregon, is used by Plaintiff to manufacture ceiling tiles.  He testified that the majority of the main building is the

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