Indiana Code

Ind. Code § 33-26-6-3 (2026)

Scope of proceeding; law governing

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaInd. Code CornellLII Search CasesGoogle Scholar

     Sec. 3. (a) Subject to subsection (b), with respect to determinations as to whether any issues or evidence may be heard in an original tax appeal that was not heard in the administrative hearing or proceeding, the tax court is governed by the law that applied before the creation of the tax court to appeals to trial courts of final determinations made by the department of state revenue and the state board of tax commissioners.

     (b) Judicial review of disputed issues of fact must be confined to:

(1) the record of the proceeding before the Indiana board of tax review; and

(2) any additional evidence taken under section 5 of this chapter.

The tax court may not try the case de novo or substitute its judgment for that of the Indiana board of tax review. Judicial review is limited to only those issues raised before the Indiana board of tax review, or otherwise described by the Indiana board of tax review, in its final determination.

     (c) A person may obtain judicial review of an issue that was not raised before the Indiana board of tax review only to the extent that the:

(1) issue concerns whether a person who was required to be notified of the commencement of a proceeding under this chapter was notified in substantial compliance with the applicable law; or

(2) interests of justice would be served by judicial resolution of an issue arising from a change in controlling law occurring after the Indiana board of tax review's action.

[Pre-2004 Recodification Citation: 33-3-5-14.]

As added by P.L.98-2004, SEC.5.

 

Notes of Decisions
Cited in 18 cases (8 in the last 5 years), 2007–2024 · leading case: Hutcherson v. Ward, 2 N.E.3d 138 (Ind. T.C. 2013).
Hutcherson v. Ward, 2 N.E.3d 138 (Ind. T.C. 2013). “Code § 33-26-6-3(b)(1) (2013). Moreover, the Tax Court's review is generally limited to the issues raised before the Indiana Board or otherwise described in its final determination.”
St. George Serbian Orthodox Church v. Lake Cnty. Prop. Tax Assessment Bd. of Appeals, 905 N.E.2d 539 (Ind. T.C. 2009). · cites it 2× “at 8 (citing Ind.Code Ann. § 33-26-6-3(b) (West 2009) (which states that this Court's review of Indiana Board decisions "is limited to only those issues raised before the [Indiana Board], or otherwise described by the [Indiana Board], in its final determination")).”
Jones v. Jefferson Cnty. Assessor, 6 N.E.3d 1048 (Ind. T.C. 2014). · cites it 2× “, Ind. Code §§ 33-26-6-3 (b), -4 (2014); Ind.”
Nancy A. Daw, Stephen L. Hoback, Co-Trs. of Sagacious Sentinel Sycamore Revocable Trust v. Hancock Cnty. Assessor, 116 N.E.3d 1 (Ind. T.C. 2018). · cites it 2× “1981) ; see also Ind. Code § 33-26-6-3 (2018).”
Idris v. Marion Cnty. Assessor, 12 N.E.3d 331 (Ind. T.C. 2014). · cites it 4× “1990); Ind. Code § 33-26-6-3 (b) (2014). Consequently, the Court finds that Idris has waived this argument because Kamenova could have, but failed to, present it to the Indiana Board.”
Grant Cnty. Assessor v. Randy & Sara Ballinger (Ind. T.C. 2020). · cites it 3× “, I.C. § 33-26-6-3. 13 evidence). Accordingly, in the absence of market-based evidence, the Court cannot conclude that the Ballingers’ use of the DLGF’s 2018 statewide capitalization rate weakens the probative value of their income approach simply because the memorandum did not…”
Chris Bougie v. Kosciusko Cnty. Assessor (Ind. T.C. 2024). · cites it 3× “I.C. § 33-26-6-3. If the Court were to consider this belatedly raised issue, the outcome wouldn’t be different because the Board analyzed the conflicting evidence and determined that Bougie’s upstairs was substantially finished living space, meaning that the exception would have…”
Shoot v. Anderson Twp. Assessor, 868 N.E.2d 79 (Ind. T.C. 2007). · cites it 4× “I.C § 33-26-6-3. Consequently, the Shoots could have moved to supplement the administrative record with a sworn affidavit from the Madison County Assessor stating that May 3 was indeed the date the Shoots filed their appeals.”
Kathryn Gillette v. Brown Cnty. Assessor (Ind. T.C. 2016). “CODE § 33-26-6-3(b) (2016) (limiting the Court’s review to the issues raised by litigants during the Indiana Board proceedings or the issues considered in the Indiana Board’s final determination).”
Starke Cnty. Assessor v. Porter-Starke Servs., Inc. (Ind. T.C. 2017). “) The Indiana Board did not grant the exemption based on whether or not it was a public agency, but granted the exemption because it concluded the property was used for a charitable purpose.”
Square 74 Assocs. LLC v. Marion Cnty. Assessor (Ind. T.C. 2019). “CODE § 33-26-6-3(b) (2019) (limiting the Court’s review to the issues raised by litigants during the Indiana Board proceedings or the issues discussed by the Indiana Board in its final determination).”
Elkhart Cnty. Assessor v. Lexington Square LLC (Ind. T.C. 2023). “CODE § 33-26-6-3 (2023) (indicating that in cases such as this, the Court is precluded from considering issues and evidence not presented to the Indiana Board).”
— Ind. Code § 33-26-6-3(b) — 13 cases
St. George Serbian Orthodox Church v. Lake Cnty. Prop. Tax Assessment Bd. of Appeals, 905 N.E.2d 539 (Ind. T.C. 2009). “at 8 (citing Ind.Code Ann. § 33-26-6-3(b) (West 2009) (which states that this Court's review of Indiana Board decisions "is limited to only those issues raised before the [Indiana Board], or otherwise described by the [Indiana Board], in its final determination")).”
Idris v. Marion Cnty. Assessor, 12 N.E.3d 331 (Ind. T.C. 2014). “1990); Ind. Code § 33-26-6-3 (b) (2014). Consequently, the Court finds that Idris has waived this argument because Kamenova could have, but failed to, present it to the Indiana Board.”
Shoot v. Anderson Twp. Assessor, 868 N.E.2d 79 (Ind. T.C. 2007). “I.C § 33-26-6-3. Consequently, the Shoots could have moved to supplement the administrative record with a sworn affidavit from the Madison County Assessor stating that May 3 was indeed the date the Shoots filed their appeals.”
Kathryn Gillette v. Brown Cnty. Assessor (Ind. T.C. 2016). “CODE § 33-26-6-3(b) (2016) (limiting the Court’s review to the issues raised by litigants during the Indiana Board proceedings or the issues considered in the Indiana Board’s final determination).”
Starke Cnty. Assessor v. Porter-Starke Servs., Inc. (Ind. T.C. 2017). “) The Indiana Board did not grant the exemption based on whether or not it was a public agency, but granted the exemption because it concluded the property was used for a charitable purpose.”
— Ind. Code § 33-26-6-3(b)(1) — 1 case
Hutcherson v. Ward, 2 N.E.3d 138 (Ind. T.C. 2013). “Code § 33-26-6-3(b)(1) (2013). Moreover, the Tax Court's review is generally limited to the issues raised before the Indiana Board or otherwise described in its final determination.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.