Mobile Home Park Property Tax Appeals

It depends on the state and how each home is titled, and getting this right is one of the most common errors we see in MHC assessments. Tenant-owned homes are usually taxed separately to the resident — sometimes as personal property, sometimes through a specific manufactured-home tax — and should not be rolled into the operator's real-property assessment. Park-owned homes used as infill rentals are a different question: the home itself often has value as personal property or business enterprise value, but that value is not real property and should not lift the land-and-pads assessment. Assessors who include park-owned home value in the real property roll are double-counting against the operator. Our commercial property tax assessment guide explains the real-versus-personal distinction and why it matters on every MHC appeal.

For an MHC, the income approach starts with lot rent — not unit rent — multiplied by the number of occupied pads, then adjusted for vacancy that captures both empty pads and unrented infill homes. Operating expenses for an MHC are heavier per income dollar than for a typical apartment complex because of utility infrastructure, road maintenance, and management overhead spread across a relatively low rent base, and capital reserves for water, sewer, and street repair should be deducted before capitalizing net operating income. The resulting NOI is then capitalized at an MHC-appropriate cap rate, which historically has run wider than apartment cap rates. Our guide to cap rates and commercial property taxes explains why cap rate selection is one of the most disputed inputs in any income-based appeal.

Vacancy in an MHC has two layers, and assessors who only look at the first layer almost always overstate income. The first layer is empty pads — lots with no home on them at all — and the second layer is unrented park-owned infill homes that are sitting vacant on otherwise occupied pads. Both reduce the income the park can actually generate, and both should be reflected in the income approach. High-turnover parks, parks where infill home delivery has stalled, and parks in markets with weak in-migration carry vacancy profiles that the assessor's stabilized assumption simply will not match. Documenting actual occupancy with rent rolls and a pad-by-pad inventory is foundational evidence for an appeal — our property tax appeal evidence resource walks through what we use to build the case.

Mobile home park cap rates have historically been wider than multifamily cap rates because investors price in the operational complexity, infrastructure liability, and tenant-base risk that come with park ownership. That spread has compressed over the past several years as institutional capital has entered the asset class, but five-star communities and one-star communities still trade at very different cap rates — quality, location, infrastructure condition, and resident demographics all matter. Assessors who simply plug in the local apartment cap rate are using the wrong number, and the resulting indicated value is almost always too high. Our team sources MHC-specific transaction data and industry references from groups like the Manufactured Housing Institute to anchor cap rate arguments to the actual market — and pairs that with the analysis covered in our cap rate property tax resource.

Yes, and the differences shape both how the park is taxed and how the appeal is filed. In Michigan, manufactured housing communities are typically classified as commercial real property for the pads and infrastructure, while residents may pay a separate specific tax on their homes — and purchases of an MHC can also trigger taxable value uncapping for the operator. In Ohio, operators challenge MHC assessments through the county Board of Revision, generally by March 31 of the year following the tax year at issue. In Indiana, appeals proceed through the county PTABOA and, if necessary, the IBTR. We track each state's deadlines in our property tax appeal deadlines guide.

The strongest MHC appeals are built on actual park data — not market-wide averages. We start with a pad-by-pad rent roll showing lot rent, occupancy status, and whether each home is tenant-owned or park-owned, then layer in operating expense statements, capital reserve history, and infrastructure condition reports. Comparable sales of similarly-rated MHCs (five-star versus one-star, similar pad count, similar geographic submarket) provide a sales-comparison check on the income approach value. Operators should also document any deferred infrastructure liabilities — aging septic systems, private roads needing repaving, electrical service upgrades — because those costs reduce the cash flow a buyer would pay for. Our team handles the entire evidence build during the property tax appeal process on a contingency basis — see our property tax appeal cost resource for fee details.