Property Tax Resources

3 minutes reading time (584 words)

New Opportunity for Hotel Property Tax Reductions

"In 2001, the Appraisal Institute developed Course 800, to provide the theoretical and analytical framework for separating the tangible and intangible assets of operating properties."

By Raymond Gray, Esq., as published by Hotel News Resource, December 7th, 2007

Disputes over hotel property taxes continue to mount all across the country and basically for one reason. Taxing authorities attempt to include both the real estate and the non-real estate values in developing their tax assessments when the law states that property taxes can be levied against only the real estate.

The appraisal profession established standards requiring that real estate must be separated from non-real estate interests for valuation purposes. Although the message is abundantly clear, the separation and measurement of the value of the tangible and intangible assets of operating properties, such as hotels, has been a challenge.

In 2001, the Appraisal Institute developed Course 800, to provide the theoretical and analytical framework for separating the tangible and intangible assets of operating properties. In 2005, Course 800 was slated for updating by the Institute and should have returned to the Institute education schedule in short order.

However, it appears that the course was lost in the rush to redevelop the entire Appraisal Institute curriculum due to the significant change in required hours for licensing and certification mandated by the Appraisal Foundation. Thus, the course was not offered by the Institute, leading a number of taxing jurisdictions and their experts to claim that Course 800 had been repudiated by the Institute and that the principles of the course were inapplicable to hotel valuation. The key underlying principles included economic and business value concepts such as:

  1. Defining and describing the 'total assets of the business' as distinguished from the 'going concern' concept,
  2. Providing a methodology to segregate and value individual income streams associated with a business enterprise, and
  3. Defining and describing the concept of 'capitalized economic profit'.

The Appraisal Institute has recently contracted with several members of the original development team, plus a couple of new contributors, to update Course 800. The preliminary outline suggests much of the original content will be incorporated in the update, especially the economic principles and business value concepts. There will be more real property case studies - highlighting the fact that this is not a 'hotel valuation course', but a course on valuing each of the value components of an operating property. The new course, anticipated to hit the market in mid-to-late 2008, is likely to take the form of a two-day seminar.

Hotel owners and managers will benefit greatly from the 'new Course 800'. As the appraising and assessing community become better educated on the principles espoused in this updated course, property owners and managers will find even greater success in appealing tax valuations that include anything other than tangible property.

raymondgray154x231pxRaymond Gray is a partner with the Austin, Texas law firm of Popp, Gray & Hutcheson. The firm devotes its practice to the representation of taxpayers in property tax disputes and is the Texas member of the American Property Tax Counsel (APTC), the national affiliation of property tax attorneys. Mr. Gray can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it..

421a Changes Increase Property Taxes
Property Tax Bills Arrive, as Does the Deadline to...

American Property Tax Counsel

Recent Published Property Tax Articles

Navigating D.C.’s Tax Rate Maze

An evolving and imperfect system has increased property taxes for many commercial real estate owners.

If you own or manage real property in the District of Columbia and are wondering why your real estate tax bill has gone up in recent years, you are...

Read more

Texas' Taxing Times

​How changes to the Texas property tax law may impact you, and how COVID-19 plays a role this season.

Property taxes are big news in Texas. Last year, property taxes were a primary focus of the 86th Legislature, and Gov. Greg Abbott deemed property tax relief so important that he declared...

Read more

Higher Property Tax Values in Ohio

The Buckeye State's questionable methods deliver alarmingly high values.

A recent decision from an Ohio appeals court highlights a developing and troubling pattern in the state's property tax valuation appeals. In a number of cases, an appraiser's misuse of the highest and best use concept has led to extreme overvaluations. Given...

Read more

Member Spotlight


Forgot your password? / Forgot your username?