Appeal guide · Texas
How to appeal a commercial assessment in Harris County
8 steps from the notice to the Harris County Appraisal Review Board (ARB) and beyond, with the forms, exchange deadlines and mistakes that decide commercial cases here.
Deadline
May 15 or the 30th day after the notice of appraised value is delivered, whichever is later (Tex. Tax Code §41.44(a)(1))
Where to file
HCAD Electronic Filing and Notice System (iFile), with iSettle settlement offers for eligible owners
Statute
Tex. Tax Code §41.41 and §41.44 (protest); Chapter 42 (judicial review)
The process, in order
Most commercial protests start with an informal meeting with an HCAD appraiser, and many settle there with a signed agreement. Unresolved protests go to an ARB panel of at least three members, or to a single-member panel if the owner asks for one in the notice of protest or at least 10 days before the hearing. Because Harris County exceeds 1.2 million residents, owners of commercial, industrial, utility and multifamily accounts above the Comptroller's indexed minimum (set at $50 million for 2020) can request a special panel whose members hold credentials such as a JD, MBA, CPA, MAI or CAE. Owners may appear in person, by telephone or videoconference, or by affidavit.
Forms you will need
- +Form 50-132, Property Owner's Notice of Protest
- +Form 50-162, Appointment of Agent for Property Tax Matters
- +Form 50-283, Property Owner's Affidavit of Evidence
- 1
March through April, when notices are delivered
Review the notice and HCAD records
Confirm building area, class, year built and land size in HCAD's records, and compare the new appraised value with the prior year and with any rendered value.
- 2
Before filing, if a consultant will handle the protest
Appoint the agent
File Form 50-162 so HCAD sends notices, evidence and settlement communications to the agent rather than the owner.
- 3
By May 15 or 30 days after notice delivery, whichever is later
File the protest
File through iFile or on Form 50-132, selecting both incorrect market value and unequal appraisal so both arguments stay available.
- 4
As soon as the hearing notice arrives (at least 15 days before the hearing)
Request HCAD's evidence
Ask for the data, schedules and formulas HCAD will introduce under §41.461. Anything not delivered at least 14 days before the hearing cannot be used against the owner.
- 5
Before the formal hearing
Informal meeting with an HCAD appraiser
Present the normalized income analysis and the uniformity grid. A signed settlement here ends the protest for the tax year.
- 6
May through October
Formal ARB hearing
Present to the ARB panel (or a requested special panel for large commercial accounts) in person, by phone or video, or by Form 50-283 affidavit. Deliver income and comparable data 14 days early where §41.43(a-3) applies.
- 7
Within 60 days of receiving the ARB order (30 days for a SOAH notice)
Choose the next forum
File in district court or request binding arbitration with the Comptroller within 60 days. A SOAH appeal needs a notice filed with the chief appraiser within 30 days and a $1,500 deposit within 90 days.
- 8
Before the delinquency date
Protect the appeal with payment
Pay at least the amount required by §42.08 so the court appeal is not forfeited; any refund is computed after the final value is set.
Mistakes that lose Harris County appeals
- Settling informally on market value alone when an unequal appraisal comparison would have produced a lower number.
- Assuming a late notice extends the deadline without confirming the delivery date and the protest deadline printed on the notice.
- Skipping the §41.461 evidence request, which gives up the chance to keep HCAD's undisclosed data out of the hearing.
- Presenting raw operating statements with debt service, depreciation and capital items still in the expense lines.
- Filing a district court petition and then trying to request arbitration; a Chapter 42 appeal on value waives the arbitration route.
Evidence rules
- 1.Request HCAD's hearing evidence under §41.461. Information the district fails to deliver at least 14 days before the hearing cannot be used except to rebut the owner's case (§41.67(d)).
- 2.The appraisal district carries the burden of proving value by a preponderance of the evidence (§41.43(a)). If the prior year's value was lowered in a protest that did not end in a written agreement, delivering income and expense statements or comparable sales at least 14 days before the hearing raises that burden to clear and convincing evidence (§41.43(a-3)).
- 3.Evidence offered by affidavit must reach the ARB before the hearing begins, and an owner appearing by telephone or videoconference must offer all evidence by affidavit (§41.45(b)).
- 4.Income and expense information provided to HCAD is confidential under §22.27 and may be disclosed only to the owner, an authorized representative, or in a property tax proceeding involving the owner.
Frequently asked
Does HCAD assess commercial property at a fraction of value?
No. Texas appraises property at 100% of market value as of January 1, and taxing units apply their rates to that value after exemptions. The only limit on commercial increases is the 20% circuit breaker for non-homestead real property at or below the indexed threshold, which under current law covers the 2024 to 2026 tax years.
Is income data I give HCAD made public?
No. Section 22.27 makes income and expense information provided to an appraisal office confidential. It can be disclosed to the owner, to a representative authorized in writing, or in a judicial or administrative property tax proceeding to which the owner is a party.
Can a commercial property in Harris County use binding arbitration?
Yes, if the ARB order values it at $5 million or less. The request and deposit go to the Comptroller within 60 days of receiving the order. Higher-value property goes to district court or, for non-industrial property above $1 million, to SOAH.
What is the equal-and-uniform standard in Texas?
Under §41.43(b)(3) and §42.26(a)(3), the owner prevails if the appraised value exceeds the median appraised value of a reasonable number of comparable properties appropriately adjusted. It compares HCAD's value to HCAD's own values, so it works even when market sales are thin.
File a stronger Harris County appeal this cycle.
ATALI ELECTRIC builds the income, sales and uniformity exhibits, fills the county forms and tracks every deadline.