Kansas Statutes Annotated

K.S.A. § 79-1436 (2026)

✓ current as of May 2026
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79-1436.

History: L. 1949, ch. 224, § 2; L. 1965, ch. 516, § 2; L. 1967, ch. 489, § 2; L. 1972, ch. 362, § 2; L. 1974, ch. 428, § 1; L. 1982, ch. 397, § 1; L. 1989, ch. 2, § 7 (Special Session); L. 1991, ch. 162, § 8; Repealed, L. 1992, ch. 131, § 10; July 1.

CASE ANNOTATIONS

1. Ratio studies may be considered in determining necessity for a reappraisal of property. Board of County Commissioners v. Brookover 198 Kan. 70, 71, 77, 422 P.2d 906.

2. Assessment and valuation of property are administrative in character; absent evidence that assessment was arrived at fraudulently, arbitrarily or capriciously, a difference of opinion as to value doesn't warrant judicial interference. Cities Service Oil Co. v. Murphy, 202 Kan. 282, 291, 295, 447 P.2d 791.

3. Ratio study held not conclusive evidence in considering valuation of interstate gas pipeline and distribution property. Northern Natural Gas Co. v. Dwyer, 208 Kan. 337, 339, 492 P.2d 147.

4. Referred to; assessment of property at 43% of fair market value arbitrary and oppressive. Gordon v. Hiett, 214 Kan. 690, 692, 522 P.2d 942.


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Notes of Decisions
Cited in 8 cases, 1968–1984 · leading case: N. Nat. Gas Co. v. Williams, 493 P.2d 568 (Kan. 1972).
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N. Nat. Gas Co. v. Williams, 493 P.2d 568 (Kan. 1972). · cites it 3× “Brookover, supra, where it was held that ratio studies provided for by K.”
Cities Serv. Oil Co. v. Murphy, 447 P.2d 791 (Kan. 1968). · cites it 2× “Brookover, supra, where it was held that ratio studies provided for by K.S.A. 79-1436 may properly be considered in determining the necessity for reappraisal to arrive at justifiable value as provided by *292 K.”
Gordon v. Hiett, 522 P.2d 942 (Kan. 1974). · cites it 2× “Each of the points is aimed at the validity of the assessment of plaintiff's property; hence, they will be considered as raising an identical question of law.”
Atchison, Topeka & Santa Fe Ry. Co. v. Lennen, 552 F. Supp. 1031 (D. Kan. 1982). “79-1437 shall be inadmissible as evidence in actions involving the assessment of property, sales of which are not required to be reported by county assessors to the director of property valuation under the provisions of K.S.A. 79-1436. This statute presents the railroads with…”
N. Nat. Gas Co. v. Dwyer, 492 P.2d 147 (Kan. 1971). “2d 791 , we held: "`Ratio studies provided for by K.S.A. 79-1436 are proper evidence of justifiable value but such evidence, standing alone, is not conclusive in establishing a basis for comparison in determining uniformity of values for assessment purposes.”
The Atchison, Topeka & Santa Fe Ry. Co. v. Michael Lennen, Union Pac. R.R. Co. v. The Dep't of Revenue of the State of Kansas, Chicago, Rock Island & Pac. R.R. Co. v. Michael Lennen, Missouri-Kansas-Texas R.R. Co. v. Michael Lennen, Burlington N., Inc. v. Philip W. Martin, 732 F.2d 1495 (10th Cir. 1984). “Kansas law prohibits the introduction of the study "in actions involving the assessment of property, sales of which are not required to be reported by county assessors to the director of property valuation under the provisions of K.S.A. 79-1436." Kan.Stat.Ann. Sec. 79-1437b.”
Panhandle E. Pipe Line Co. v. Dwyer, 485 P.2d 149 (Kan. 1971). “2d 791 , we held: "Ratio studies provided for by K.S.A. 79-1436 are proper evidence of justifiable value but such evidence, standing alone, is not conclusive in establishing a basis for comparison in determining uniformity of values for assessment purposes.”
Atchison, Topeka & Santa Fe Ry. Co. v. Lennen, 732 F.2d 1495 (10th Cir. 1984). “Kansas law prohibits the introduction of the study “in actions involving the assessment of property, sales of which are not required to be reported by county assessors to the director of property valuation under the provisions of K.S.A. 79-1436.” Kan.Stat.Ann. § 79-1437b.”
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.