May 7, 2026 Memorandum to the Board of Supervisors

Memorandum

TO:        Hon. Jennifer Allen, Chair, District 3

Hon. Dr. Matt Heinz, Vice Chair, District 2

Hon. Rex Scott, District 1

Hon. Steve Christy, District 4

Hon. Andrés Cano, District 5

CC:        Hon. Suzanne Droubie, County Assessor

              Sam Brown, Chief Deputy Civil Attorney

              Jan Lesher, County Administrator

              Jolene Christopherson, Deputy Assistant Director, Property Tax Division,

                             Arizona Department of Revenue

FROM: Brian Johnson, County Treasurer

DATE:    May 7, 2026

RE: Notice of Withholding of Tax Roll Corrections

I am writing to formally advise the Board of Supervisors and the Arizona Department of Revenue (A.R.S. § 42-16109.D) that the Pima County Treasurer’s Office is currently withholding processing of approximately 2,400 tax roll corrections associated with approximately 632 parcels for tax years 2022, 2023, 2024, and 2025, submitted by the Assessor’s Office. The tax impact of these corrections would result in recouping approximately $5.8 million of levied and spent funds from the affected districts to pay the refunds.

Under the provisions of the Arizona Revised Statutes. Pursuant to § 42-16002 and Chapter 16, Article 6, Correcting Property Tax Errors, the Treasurer’s authority to issue a corrected tax bill, tax refund, and/or update the tax roll is not automatic upon the Assessor’s request; it is triggered by a legally perfected correction.

Pursuant to A.R.S. § 11-504, I am required to correct errors in treasury accounts immediately. However, this duty implies a standard of accuracy, conformity to Arizona law, and statutory requirements in order to maintain the “checks and balances” intended by the separation of the taxing and collecting authorities.

Analysis of Tax Roll Corrections Regarding Aggregate Notices of Proposed Corrections Issued by the Pima County Assessor

by Diana L May, PhD

 AZDOR Certified Property Appraiser – Level II #1907

AZDIFI Certified Residential Real Estate Appraiser #21404

The Pima County Assessor has recently issued Notices of Proposed Correction (NOPCs) for approximately 630 properties, most addressing tax years 2022-2025.  The Pima County Treasurer’s Office (TO) has reviewed the Assessor website, a sample of tax roll correction (TRC) worksheets, an NOPC copy provided by a taxpayer, and a small sample of scanned copies of NOPCs provided by the Assessor on May 4, 2026.  This review indicates the Assessor’s actions deviate from, and do not comply with, statutory requirements under Arizona Revised Statutes Title 42, including but not limited to A.R.S. § 42-11001, 42-16251, 42-16252, 42-16256, 42-16257, and 42-13301-13302.

According to A.R.S. § 42-11001, “‘Full cash value’, for property tax purposes, means the value determined as prescribed by statute.  If a statutory method is not prescribed, full cash value is synonymous with market value, which means the estimate of value that is derived annually by using standard appraisal methods and techniques.”  This statute also notes: “‘Valuation date’, for the purposes of real property and property valued by the department, means January 1 of the year preceding the year in which taxes are levied.” In the case of these parcels, no statutory method is prescribed.  Of the three standard approaches to value, the Sales Comparison Approach (aka Market Approach), the Cost Approach, and the Income Capitalization Approach, the Assessor, with some exceptions, originally used the Cost Approach to value these properties.  In making purported error corrections to properties the TO reviewed, however, it appears that the Assessor did not use any standard appraisal methods and techniques.  Instead, prior years’ FCVs (2022–2025) were replaced with the FCV established for tax year 2026, effectively applying a single valuation date across multiple tax years in violation of statute.

For tax years 2022-2025, approximately 38,000 properties were valued using a Segregated Cost (Unit-in-Place) valuation system. Beginning in tax year 2026, the Assessor transitioned to the Comparative-Unit, i.e., Square-Foot cost valuation system using Marshall & Swift/CoreLogic data. Ryan Call of the Assessor’s Office communicated to Melanie Farrington of the TO that “He confirmed that there are over 600 parcels affected by issues that occurred during their conversion to Tyler and they discovered the CCS values were incorrect.  These will be multi-year TRC’s.”  However, the Assessor has not complied with statutes.

The review identified the following statutory deficiencies:

  1. The purported corrections do not meet the definition of an “error” under A.R.S. § 42-16251.  Rather than correcting factual mistakes, the Assessor substituted prior years’ FCVs with the 2026 FCV, reflecting an exercise of judgment or opinion.  This approach also violates A.R.S. § 42-11001 because the corrected FCVs were not “derived annually by using standard appraisal methods and techniques.”  Instead, the Assessor manipulated the improvement (IMP) portion of the FCV such that the IMP FCV plus the Land FCV equals the total 2026 FCV, either as noticed or as conveyed following an appeal.  See all examples later in this report.
  • All correction worksheets and NOPCs reviewed indicate the Assessor failed to provide an explanation of the error and the reasons for the error, as required by A.R.S. § 42-16252. See attached worksheets and NOPC copy.
  • In most cases of NOPCs issued in early 2026, the Assessor improperly corrected four prior tax years (2022–2025), exceeding the three-year limitation established by A.R.S. § 42-16256.  See examples 120-08-4900, 122-12-2790, and 110-15-2330.
  • Based on all the worksheets reviewed, the Assessor did not apply the valuation criteria in effect, i.e., Segregated Cost method, as of each applicable valuation date, in violation of A.R.S. § 42-16257.
  • In some of the worksheets reviewed, Limited Property Values (LPVs) were adjusted in a manner contrary to A.R.S. § 42-13301-13302. See example 117-02-1150.

The definition of an error per A.R.S. § 42-16251(3), particularly subsection E is: “any mistake in assessing or collecting property taxes resulting from…a valuation…that is based on an error that is exclusively factual in nature…and that is demonstrated by clear and convincing evidence such as…(ii) clerical or typographical errors in reporting or entering data that was used directly to establish valuation…” or “…(vi) any other objectively verifiable error that does not require the exercise of discretion, opinion or judgment.”  Pursuant to A.R.S. § 42-16252, a Notice of Proposed Correction must “explain the error, the reasons for the error and the proposed correction of the error.”  Examples of narrative that would be included in the NOPC:

  • Masonry wall demolished prior to Jan 1st valuation date – Remove masonry wall component from cost listing.
  • A building was incorrectly listed with an area of 12,500 square feet (Sq. Ft.).  The physical measurement of the building indicates a building area of 11,500 sq. ft. The property will be revalued based upon a building area = 11,500 Sq. Ft. at the same value / Sq. Ft. as in the noticed value.
  • A church is listed as a legal classification 1 miscellaneous use code. When applying for an exemption, it was corrected to class 2 with a religious building use code (Lions v. State Board of Equalization 2004).

In all the worksheets and NOPC documents reviewed thus far, the description of and reason(s) for the proposed correction of the Full Cash Value (FCV) are stated as, “error in value calculation.”  This generic and conclusory statement does not meet the standards of: (1) A.R.S. § 42-16251: an objectively verifiable, factual mistake that can be demonstrated by clear and convincing evidence and does not require judgment, and (2) A.R.S. § 42-16252: an explanation of the error and reasons for the error.

The correction worksheets reveal a consistent pattern: for each affected parcel, the FCVs for tax years 2022–2025 were adjusted to match the FCV for tax year 2026.  This pattern is inconsistent with a recalculation under any recognized appraisal method.  Instead, the Assessor adjusted improvement values as necessary to align total FCV with the 2026 FCV, regardless of differences in land values or prior-year conditions.  The following pages show five examples of value adjustments that illustrate different ways these adjustments were made.  See also, attached worksheets.

Examples

120-08-4900
TAX YRORIG FCVCORR FCVORIG IMP FCVCORR IMP FCVLAND FCVORIG LPVCORR LPV
2027$148,910N/A$70,110N/A$78,800$148,910N/A
2026$153,620N/A$74,820N/A$78,800$153,620N/A
2025$245,071$153,620$166,271$74,820$78,800$231,307$153,620
2024$247,084$153,620$168,284$74,820$78,800$220,292$153,620
2023$209,864$153,620$131,064$74,820$78,800$209,802$153,620
2022$199,811$153,620$121,011$74,820$78,800$199,811$153,620

The example of parcel 120-08-4900 represents the typical case of properties reviewed so far.  For tax years 2022-2027, the land values remain the same year over year.  For tax years 2022-2025, the original FCVs vary, most likely increasing with rising costs to build or declining with higher physical depreciation. For tax years 2026-2027, when the Assessor used the Marshall & Swift (M&S) Square Foot method, the FCV changed, likely due both to M&S multipliers, which change annually, and to physical depreciation, which increases with age.  These year-over-year changes in the original FCVs represent what would be expected when developing a cost approach for each valuation date.

In contrast to the original FCV patterns, the corrected FCVs follow a static pattern.  For tax years 2022-2025, the “corrected” total FCVs match the total FCV for tax year 2026, and the “corrected” improvement FCVs match the improvement FCV for tax year for 2026.  For this match to have occurred by re-running a cost approach with true error corrections (for tax years 2022, 2023, 2024, and 2025) is highly improbable if not impossible.  In contrast, note that 2027 FCV differed from the 2026 FCV, an expected pattern for different valuation dates.  For the match to have occurred for hundreds of properties is indeed impossible.  The pattern clearly indicates that the Assessor simply replaced the original improvement FCVs with the 2026 improvement FCV.  

122-12-2790
TAX YRORIG FCVCORR FCVORIG IMP FCVCORR IMP FCVLAND FCVORIG LPVCORR LPV
2027$81,600N/A$27,600N/A$54,000$81,600N/A
2026$83,340N/A$29,340N/A$54,000$83,340N/A
2025$111,062$83,340$66,062$38,340$45,000$107,878$83,340
2024$113,531$83,340$68,531$38,340$45,000$102,741$83,340
2023$97,849$83,340$52,849$38,340$45,000$97,849$83,340
2022$93,619$83,340$48,619$38,340$45,000$93,619$83,340

The example of parcel 122-12-2790 represents cases in which land values for one or more prior years differ from the land value for tax year 2026.  For 122-12-2790, the land values for the tax years 2022-2025 are $9K less than the land value for the 2026 tax year.  For tax years 2022-2025, the original FCVs vary in a manner similar to parcel 120-08-4900.  From tax year 2026 to 2027, the FCV decreased, as was the case for 120-08-4900.  These patterns are the same for the original improvements FCVs.  These year-over-year changes in original FCVs represent what would be expected when developing a cost approach for each valuation date.

As was the case for 120-08-4900, the “corrected” total FCVs for tax years 2022-2025 match the total FCV for tax year 2026, however, unlike 120-08-4900, the “corrected” improvement FCVs do not match the improvement FCV for tax year 2026.  Instead, the Assessor “corrected” these values to $9K higher than the 2026 improvement FCV, an amount equal to the difference in the land value as noted above.  The result is an exact match to the total FCV for tax year 2026. The Assessor appears to have backed into the “corrected” improvement values by deducting the land value for tax years 2022-2025 from the total FCV for tax year 2026.  These value adjustments clearly indicate goal-directed changes: To make the “corrected” total FCVs for tax years 2022-2025 match the total FCV for tax year 2026.  This example represents “corrections” to 22 other parcels (found thus far) in which the land values differed from the 2026 land value.

104-08-0870Correction made only to 2022-2024 tax years
TAX YRORIG FCVCORR FCVORIG IMP FCVCORR IMP FCVLAND FCVORIG LPVCORR LPV
2027$2,538,162N/A$1,907,000N/A$631,162$2,533,409N/A
2026$2,412,770N/A$1,781,608N/A$631,162$2,412,770N/A
2025$2,412,770N/A$1,781,608N/A$631,162$2,412,770N/A
2024$3,182,615$2,412,770$2,551,453$1,781,608$631,162$2,789,441$2,412,770
2023$2,656,610$2,412,770$2,025,448$1,781,608$631,162$2,656,610$2,412,770
2022$2,547,611$2,412,770$1,916,449$1,781,608$631,162$2,547,611$2,412,770

The 104-08-0870 example may be unique because the owner appealed the FCV for tax year 2025, which resulted in a frozen FCV for 2026.  For tax years 2022-2024, the original FCVs vary in a manner similar to parcel 120-08-4900 and therefore represent year-over-year changes that would be expected when developing a cost approach for each valuation date.  From tax year 2026 to 2027, the FCV increased after coming off the 2026 frozen value.  As was the case for 120-08-4900, the “corrected” total FCVs for tax years 2022-2024 match the total FCV for tax year 2026, however, unlike 120-08-4900, the FCV for tax year 2026 was not produced by a cost approach: It is the result of the 2025 appeal.  These value adjustments clearly indicate goal-directed changes: To make the “corrected” total FCVs for tax years 2022-2024 match the total FCV for tax year 2026.  Furthermore, this example provides stronger evidence that the Assessor did not run a cost approach to arrive at the corrected FCVs.

110-15-2330Taxpayer contacted Pima County Treasurer’s Office
TAX YRORIG FCVCORR FCVORIG IMP FCVCORR IMP FCVLAND FCVORIG LPVCORR LPV
2027$576,632Frozen$537,632Frozen$39,200$537,632Frozen
2026$936,335$576,632$897,135$537,432$39,200$936,335$576,632
2025$1,193,077$576,632$1,153,877$537,432$39,200$977,197$576,632
2024$1,236,882$576,632$1,197,622$537,432$39,200$930,664$576,632
2023$980,957$576,632$941,757$537,432$39,200$886,347$576,632
2022$928,004$576,632$888,804$537,432$39,200$844,140$576,623

Recently, the owner of 110-15-2330 contacted the Treasurer’s Office and provided a copy of the NOPC the owner received, the first copy of an NOPC reviewed because the Assessor did not provide any copies of NOPCs to the TO until May 4, 2026.  This example may be unique because the owner appealed the FCV for tax year 2026, reduced from the noticed FCV of $936,335 to $576,632.  As was the case in other examples, the “corrected” total FCVs for tax years 2022-2025 match the total FCV for tax year 2026, however, unlike the other examples, the alleged corrections are equal to the reduced value from the 2026 appeal, further evidence that the cost approach, i.e., the using the segregated cost method, was not used.

117-02-1150Correction made only to 2022 tax year
TAX YRORIG FCVCORR FCVORIG IMP FCVCORR IMP FCVLAND FCVORIG LPVCORR LPV
2027$274,530N/A$97,530N/A$177,000$161,998N/A
2026$270,853N/A$93,853N/A$177,000$154,284N/A
2025$318,675N/A$177,075N/A$141,600$146,937N/A
2024$139,940N/A$76,149N/A$63,791$139,940N/A
2023$139,940N/A$76,149N/A$63,791$139,940N/A
2022$183,491$270,853$119,700$207,062$63,791$183,491$154,284

The example of parcel 117-02-1150 is possibly unique (see attached worksheet).  As was the case for 122-12-2790, the land FCVs for 2022-2025 tax years differ from the FCV for tax year 2026.  In this example, the land values for tax years 2022-2024 are $113,209 less than the land value for the 2026 tax year.  For tax years 2022-2025, the year-to-year changes in the “original” FCVs are different because (1) the land value changed dramatically from tax year 2024 to 2025 and (2) the property was appealed and reduced for tax year 2023, with a frozen value for tax year 2024.  The appeal created a unique situation, with a significant reduction not only to the FCV and the Limited Property Value (LPV) for tax year 2023 but also to the LPVs for tax years 2024-2027 and beyond, increasing at only 5% each year until capped by the FCV or reset by a Rule B (see A.R.S. § 42-13301-13304).  The appeal for tax year 2023 lowered the FCV/LPV from $195,308/$192,666 to $139,940 (as displayed in the table above).  Due to cascading LPVs, the 2026 LPV is $29,207 lower than the 2022 LPV, but still higher than the 2023-2025 LPVs: This appears to be the reason the Assessor chose to “correct” only tax year 2022.

Like the other examples, the “corrected” total FCV for tax year 2022 matches the total FCV for tax year 2026, however, unlike the other examples, the 2022 FCV was increased, and dramatically so.  The Assessor “corrected” the improvement FCV to $113,209K higher than the 2026 improvement FCV.  The result is an exact match to the total FCV for tax year 2026.  As in the 122-12-2790 example, the Assessor appears to have backed into the “corrected” improvement FCV by deducting the land value for tax year 2022 from the total FCV for tax year 2026 to make the “corrected” total FCV for tax year 2022 match the total FCV for tax year 2026.

Summary

All the tax roll correction worksheets and NOPCs reviewed indicate that the Assessor issued NOPCs with the goal of reducing the property taxes for up to four prior tax years on only ~630, or 1.7%, of 38,000 properties valued using the Cost Approach.  The Assessor achieved this goal through purported error correction to Full Cash Values, effectively reducing the Limited Property Values of prior tax years to equal the Limited Property Value of the 2026 tax year.  Examples provided:

120-08-4900: A typical example where the land FCVs of prior years match the land FCV for the 2026 tax year, and the “corrected” improvement FCVs and “corrected” total FCVs equal those for tax year 2026.

122-12-2790: An example where (1) the land FCVs of prior tax years differ from the land FCV for the 2026 tax year, (2) the “corrected” total FCVs equal those for tax year 2026, but (3) the “corrected” improvement FCVs differ from the 2026 improvement FCV, offsetting the difference in land values.

104-08-0870: An example in which the Assessor set the FCV for the 2026 tax year as a freeze following an appeal of the 2025 FCV and therefore did not run a cost approach to arrive at the 2026 FCV.  In this example, the Assessor issued NOPCs only for tax years 2022-2024, with “corrections” effectively based upon the reduced FCV resulting from the 2025 appeal.

110-15-2330: An example in which the reduced 2026 FCV, as the result of a taxpayer appeal, was used to simply replace the 2022-2025 FCVs.

117-02-1150: An example where (1) the land FCVs for prior tax years differ from the land FCV for the 2026 tax year, (2) the “corrected” total FCV for the 2022 tax year equals the 2026 total FCV, and (3) the “corrected” improvement FCV differs from the 2026 improvement FCV.  What makes this example potentially unique is (1) the cascading LPVs following a 2023 appeal created a large gap between the 2026 FCV and 2026 LPV; (2) the “corrected” 2022 improvement FCV increased—significantly so—to a value $113,209 higher than the 2026 improvement FCV; (3) the “corrected” total FCV for the 2022 tax year increased, significantly so; and (4) while the 2022 total FCV increased, the 2022 LPV simultaneously decreased, in violation of A.R.S. § 42-13301-13304, which in this case prescribes no change to the 2022 LPV.

All worksheets (see attached examples) reviewed show that the Assessor “corrected” each parcel so that (1) the prior tax year FCVs equal the total 2026 FCV and (2) the prior tax year LPVs equal the 2026 LPV.  The 2nd, 3rd, 4th and 5th examples indicate that the Assessor simply “plugged” the 2026 total FCV into the “corrected” total FCV of prior tax years and then manipulated the “corrected” improvement FCVs of prior years: The manipulated improvement FCVs equal the 2026 total FCV minus the land value of prior years.  The 4th example clearly shows that the Assessor disregarded A.R.S. § 42-13301-13304 and simply plugged the 2026 LPV into the “corrected” LPV of the prior tax year.

In summary, the Assessor’s actions reflect a systematic substitution of 2026 values for prior tax years rather than the correction of factual errors as required by law. This approach fails to comply with multiple provisions of A.R.S. Title 42 governing property valuation and error correction procedures.  In conclusion, the Assessor has created a “special class” of ~630 properties during tax years 2022-2025 that are no longer subject to: (a) the same cost valuation methodology as the other ~37,370 properties valued on cost and (b) the same annual valuation dates as the rest of Pima County.

Attachment A   Approximate Tax Roll Corrections (Negative Distributions) from Assessor’s NOPCs  by Taxing Authority
 
Taxing Agency2022 Debit2023 Debit2024 Debit2025 DebitTotal 4 Years 
Pima County Primary$374,814$398,229$469,932$547,972$1,790,947 
PC Library District$52,726$54,548$63,479$72,888$243,641 
PC Flood District$31,280$32,304$37,501$42,970$144,055 
PC Secondary (Debt Service)$30,941$21,847$14,331$15,042$82,161 
      
       
Pima Community College$124,519$127,129$143,651$159,075$554,374 
 
CAWCD$13,537$13,903$16,050$18,291$61,781 
JTED$4,835$4,965$5,732$6,532$22,064 
Fire Assistance Fund$3,713$3,734$4,185$4,573$16,205 
 
 
TUSD Primary$264,165$262,612$305,501$235,229$1,067,507 
TUSD Secondary$21,858$19,121$49,079$155,123$245,181 
Marana Unified SD Primary$40,652$29,244$18,330$23,066$111,292 
MUSD Secondary$21,197$18,594$12,060$15,517$67,368 
Flowing Wells Primary$13,191$12,677$15,678$18,320$59,866 
Flowing wells Secondary$10,214$10,860$15,854$18,393$55,321 
Amphitheater SD Primary$51,104$58,938$71,148$78,139$259,329 
Amphitheater SD Secondary$18,214$21,438$25,702$32,581$97,935 
Sunnyside SD Primary$15,166$14,174$17,542$20,968$67,850 
Sunnyside SD Secondary$3,663$3,202$16,703$21,684$45,252 
Tanque Verde SD Primary$9,040$8,284$1,473$2,507$21,304 
Tanque Verde SD Secondary$4,028$1,832$685$1,164$7,709 
Ajo SD Primary$2,380$2,458$2,683$2,968$10,489 
Catalina Foothills Primary$1,635$2,593$3,415$4,783$12,426 
Catalina Foothill Secondary$749$1,213$1,630$2,303$5,895 
Vail SD Primary$9,120$8,502$9,963$12,152$39,737 
Vail SD Secondary$7,501$6,811$8,685$9,856$32,853 
Sahuarita Primary$11,196$9,574$4,087$16,838$41,695 
Sahuarita Secondary$8,975$8,416$3,558$12,268$33,217 
San Fernando SD Primary$168$170$301$543$1,182 
Empire Elementary Primary$934$629$659$685$2,907 
Continental SD Primary$7,196$9,475$6,714$9,784$33,169 
Continental SD Secondary$1,461$1,701$2,069$2,546$7,777 
Altar Valley Primary$240$276$265$248$1,029 
Altar Valley Secondary$44$54$52$48$198 
City of Tucson (combined)$79,880$59,440$73,974$80,223$293,517 
City of South Tucson$524$716$792$10,549$12,581 
Drexel Heights FD$3,509$4,063$4,605$5,206$17,383 
Sabino Vista FD$238$278$308$341$1,165 
Avra Valley FD$476$686$822$1,012$2,996 
Picture Rocks FD$1,332$1,534$1,960$1,722$6,54 
Northwest FD$39,489$30,846$24,057$30,072$124,464 
Three Points FD$838$1,006$726$1,377$3,947 
Golder Ranch FD$12,235$19,306$18,273$25,257$75,071 
Corona de Tucson FD$154$201$305$408$6,548 
Rincon Valley FD$523$409$553$738$124,464 
Arivaca FD$2,443$2,799$3,789$4,962$13,993 
Sonoita Elgin FD$731$509$635$717$2,592 
Green Valley / Santa Rita FD$19,897$13,448$16,588$16,506$66,439 
Marana Domestic Water Imp D$48$73$70$66$257 
Ajo Lukeville Health District$432$469$537$609$2,047 
Total$1,323,205$1,305,290$1,496,691$1,744,821$5,870,007 
Parcel Count:613611615617 
 
Interest Payments with Refunds 
Months: Nov. TY -> June 20264331197 
(second half payments)3725131 
Rate – 8%0.6667%0.6667%0.6667%0.6667% 
Interest$352,855$243,654$159,647$46,529$802,684