Protest Information

Every spring, Comal County property owners whose assessed value has increased over the last year (or is the Reappraisal area that year) will receive a Notice of Appraised Value. This notice contains three important values:

Market value: This is the value based on what your property would sell for as of January 1.
Appraised value: This is the reduced value of your property based on limitations provided by having a homestead exemption, circuit breaker limitation or special valuation.
Taxable value: This is the appraised value minus any exemption amounts or special valuations. It is the value used to calculate your property taxes for each taxing unit.

If you received a Notice of Appraised Value, the Notice of Protest form is enclosed. If you did not receive a Notice of Appraised Value, you can view your property’s values using the property search feature of our website.   You may still file a protest, even if you did not receive a Notice of Appraised Value.

The deadline to file your protest is May 15 or 30 days after your Notice is mailed, whichever is later. Click here for a copy of the Notice of Protest if you did not receive a Notice of Appraised Value.  You do not have to file a protest on the form provided. A protest in any written format will suffice providing it provides the required information (name of property owner, the property identification number or address and protest reason).  Your protest must be filed with the Appraisal District by May 15 or the deadline date indicated on your Notice of Appraised Value if you received one. 

If you choose to protest the value of your property, you can initiate the protest in one of several ways:

• Online
  • This is the easiest and fastest way to initiate and manage your protest. If you qualify, then please use our E-File Portal to log in.  Click here to know if qualify for Electronic Filing. By filing online, you will receive an immediate confirmation that your protest has been filed. Additionally, you will be able to upload comments and evidence related to your protest, review evidence from the appraisal district, and accept/decline any settlement offer through your online account. If you do not have an account, you can set one up by using the property owner ID and pin number on your Notice of Appraised Value. If you do not have a property owner ID or pin number, please email us at comalad@co.comal.tx.us for assistance.  Click here for screenshots of managing your online protest.
• By Mail
  • You can send us your protest form by mail at:
    Comal Appraisal District
    900 S. Seguin Avenue
    New Braunfels TX 78130
• In-Person
  • You can drop off your protest form at our office during normal business hours (8am-5pm):
    900 S. Seguin Avenue
    New Braunfels TX 78130
• By Email
  • You can email your protest form to:  comalad@co.comal.tx.us (please send in PDF format)

Protests received via US Mail, email or at the front counter are manually entered by an employee in the order it was received.  Please note that we receive tens of thousands protests yearly and submitting them this way could delay the opening and processing of your protest record.

If you file a protest, you will receive written notice of the date, time and place set for the hearing at least 15 days in advance of your hearing.  At the time you receive notification of your hearing date, you will also receive a copy of Taxpayer Assistance Pamphlet, a copy of the ARB Hearing Procedures and an evidence packet for you to review.

Informal meetings with a CAD appraiser will be offered 30 minutes before the scheduled ARB hearing. If you do not accept a settlement offer from the appraisal district during the informal meeting, you will be given the opportunity to be heard by the Comal Appraisal Review Board (ARB).

Hearings with the Appraisal Review Board will be scheduled for May through July.  Informal meetings with district appraisers may begin in April.

THE INFORMAL MEETING

APPRAISAL REVIEW BOARD (ARB) HEARINGS

APPEALING ARB DECISION

FREQUENTLY ASKED QUESTIONS

RESOURCES

The Informal Meeting

The informal meeting is intended to allow the property owner to provide more detailed information about the property.  If you are able to resolve your protest during the informal meeting, your hearing with the ARB will be cancelled.  There will only be one informal meeting per property. 

When a property owner files their protest, they can submit evidence to the appraisal district that shows why they believe their market value should be lowered. Property owners who file their protests online can upload their evidence, review the appraisal district’s evidence, and review a settlement offer through their online accounts.  Once a settlement has been accepted, the protest is considered closed and cannot be reopened or taken to the ARB.

Property owners may submit their protest and evidence through our online portal, by mail (900 S. Seguin Avenue, New Braunfels, TX 78130), or by hand delivery to our office (900 S. Seguin Avenue).  If submitting protest and/or evidence via email, please attach in PDF format and email to comalad@co.comal.tx.us.

If a property owner does not accept a settlement offer from the appraisal district during the informal meeting they will be given the opportunity to be heard by the Comal Appraisal Review Board (ARB).

Appraisal Review Board (ARB) Hearings

The Comal Appraisal Review Board (ARB) is an independent group of citizens authorized to resolve problems with appraisals or other concerns allowed by protest. The ARB hears testimony and reviews evidence to determine property owner protests that were not resolved during the informal process. 

During an ARB hearing, both a property owner and a representative from the appraisal district will present their evidence and take questions from a panel of ARB members. Following this presentation, the panel will make a decision regarding the protest. Hearings last 15 to 20 minutes. Within 30 days, the property owner will receive a Notice of Final Order via certified mail.

You should not contact ARB members outside of the hearing.  The law requires the ARB members to sign an affidavit stating that they have not talked about  your case before the ARB hears it.

The ARB hearing process is typically held from May through July of each year. Property owners will be allowed to participate in their hearings in several ways:

By phone/videoconference: Property owners will be allowed to present their case via a telephone/videoconference hearing. Property owners must submit their evidence prior to their hearing on a notarized affidavit.

By affidavit: Property owners will be allowed to submit their evidence and arguments by written affidavit that has been notarized.

In person: Property owners will be allowed to attend an in-person hearing at CAD’s office.

The ARB will notice property owners with information on their scheduled hearing date and time at least 15 days before their scheduled hearing. That notification will also contain information on how to attend a phone hearing, submit an affidavit, or request an in-person hearing. Property owners who request electronic communication will be sent this information through the online portal. Property owners who cannot make the date/time of their hearing before the Appraisal Review Board may request that their hearing be rescheduled…if the request was made prior to date of hearing. Property owners who wish to be represented by someone else (such as family member, neighbor, or friend) during their protest hearing should provide written authorization from the owner of record.

All property owners who file an online protest will have access to the CAD’s evidence packet via the online portal. To access this evidence, you must have an online account using the property owner ID and pin number on your Notice of Appraised Value.

Property owners who wish to appeal the decision of the ARB may do so by appealing to District Court, filing a binding arbitration or filing with the State Office of Administrative Hearings (SOAH).  Please see “Appealing ARB Decision”.

Appealing ARB Decision

What Can I Do If I Do Not Agree With A Decision Of The Appraisal Review Board?

If you have a hearing before the Appraisal Review Board on a protest, a Property Tax Code 25.25 motion, or on failure to receive a required notice from the District, the Appraisal Review Board will mail you their decision by certified mail, return receipt requested. If you do not agree with the decision of the ARB, you may have three options for appeal:

Appeal to District Court:  This option is available to all property owners.  To appeal, you must file a lawsuit with the district court no later than 60 days after receiving the written notice of the ARB’s decision. It is recommended that you consult with an attorney if you decide to appeal to district court.

Binding Arbitration:  This option is available on certain properties as outlined below in the Schedule of Deposits.  Binding arbitration is only available for market/appraised value or equity determinations. Please visit the Comptroller website for more information regarding Binding Arbitrations.

Schedule of Deposits:

• Residence homestead with an appraised value of $500,000 or less: $450
• Residence homestead with an appraised value more than $500,000:  $500
• Other than residence homestead with an appraised value of $1,000,000 or less:  $500
• Other than residence homestead with an appraised value over $1,000,000 but no more than $2,000,000:  $800
• Other than residence homestead with an appraised value over $2,000,000 but no more than $3,000,000:  $1,050
• Other than residence homestead with an appraised value over $3,000,000 but no more than $5,000,000:  $1,550

State Office of Administrative Hearings (SOAH):  This option is available on properties valued at more than $1 million.  Appeals to SOAH are limited to appraised or market value appeals and exclude industrial properties.  A Notice of Appeal by Property Owner to SOAH must be filed with the District within 30 days after receiving the written notice of the ARB’s decision.  Within 90 days of receiving the ARB’s decision, a deposit of $1,500 made payable to SOAH must be filed with the District.  The District will forward the deposit and appeal form to SOAH and request the appointment of a qualified administrative law judge to hear the appeal.

For more information regarding SOAH appeals, consult Texas Government Code Chapter 2003 and related SOAH rules or visit their website.  If you need legal advice, you should consult an attorney.

TAX PAYMENT REQUIREMENTS:

If you file any type of appeal, you are required to make a timely payment of taxes, in the amount of taxes not in dispute, before the delinquency date. You may ask the court to excuse you from prepaying your taxes; to do so, you must file an oath attesting to your inability to pay the taxes in question and argue that prepaying them would restrain your right to go to court on your protest. The court will hold a hearing and decide the terms or conditions of your payment.

Frequently Asked Questions

Resources

How to Present Your Case at the Appraisal Review Board Hearing for Homeowners

How to Present Your Case at the Appraisal Review Board Hearing for Small Businesses

Additional Resources

Taxpayer Assistance Pamphlet

Protest Forms