Cook County Board of Review Evidence Requirements

Common Issues in Property Tax Appeal Valuation Evidence

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The Cook County Board of Review places significant emphasis on the quality, organization, and credibility of valuation evidence submitted during a property tax appeal. In many cases, appeals are weakened not by the overall argument itself, but by unsupported assumptions, incomplete documentation, or improperly presented appraisal evidence.

For attorneys handling commercial and multi-family property tax appeals, understanding how valuation evidence is reviewed can materially impact the strength of an appeal.

Comparable Sales Selection Matters

One of the most common weaknesses in Board of Review and PTAB valuation evidence is the selection of comparable sales that differ significantly from the subject property in:

• Gross building area
• Unit count
• Unit mix
• Age and condition
• Location
• Land-to-building ratio
• Occupancy characteristics

While adjustments may account for certain differences, excessive variation between the subject and comparable properties can reduce the reliability of the analysis.

Particular scrutiny is often placed on:

• Large adjustments
• Unsupported market condition adjustments
• Inconsistent capitalization rates
• Sales occurring outside the relevant assessment period
• Reliance on distressed or non-arm’s-length transactions

Income and Expense Documentation

For income-producing properties, the Board generally expects property-specific financial evidence rather than generalized market assumptions.

Important supporting documentation may include:

• Historical operating statements
• Current rent rolls
• Lease summaries
• Vacancy history
• Capital expenditure history
• Real estate tax history
• Market leasing data

Rent rolls should generally reflect records maintained in the ordinary course of business rather than attorney-prepared summaries.

Appraisal Report Quality

Appraisals submitted in support of tax appeals should present:

• Clear adjustment support
• Consistent methodology
• Credible market evidence
• Logical reconciliation
• USPAP compliance

Particular attention is often given to:

• Comparable selection
• Highest and best use conclusions
• Vacancy assumptions
• Capitalization rate support
• Treatment of real estate taxes
• Internal consistency between approaches

Reports containing unsupported adjustments or inconsistent conclusions may receive reduced evidentiary weight.

Vacancy and Collection Loss Support

Generalized vacancy assumptions may carry limited persuasive value without property-specific evidence.

Support for elevated vacancy claims may include:

• Historical occupancy trends
• Leasing history
• Marketing efforts
• Tenant rollover exposure
• Deferred maintenance issues
• Market absorption conditions

For distressed occupancy situations, evidence demonstrating the cause and duration of vacancy can become particularly important.

Practical Considerations for Attorneys

Strong valuation evidence is typically:

• Well organized
• Internally consistent
• Market supported
• Property specific
• Easy for reviewing bodies to follow

In many appeals, clarity and credibility can be just as important as the valuation conclusion itself.