We were running the analyzer against a small downtown Burleson property — a 1980 residential bungalow, 869 square feet, classified A1 — Real, Residential, Single Family by Johnson CAD. The kind of property that should produce a boring protest, if one at all. Instead the analyzer flagged something unusual: a single-year land-value jump from $48,300 to $207,000.
+329%. No new construction. No re-platting. No change in legal land classification. The improvements line stayed flat at $54,559. The lot stayed 0.198 acres. Only the dirt was repriced.
That kind of move would be unusual in isolation. But pulling the rest of the neighborhood, we found this property wasn't being singled out — it was part of a coordinated repricing of a small cohort of similarly-situated downtown parcels. All A1 residential. All in the same neighborhood code. All repriced in the same year, by similar percentages. And none of them ever had their legal classification formally changed.
That's the pattern this post is about, and we think it's repeating across Texas in 2024 and 2025.
The neighborhood, by the numbers
Johnson CAD's neighborhood code 126.2552 covers the original Burleson townsite and adjacent blocks. It contains 140 parcels classified A1 (Real, Residential, Single Family). We pulled the land value per square foot of lot for every one of them.
Distribution of all 140 A1 parcels by land $/sqft tier
| Tier | Peer count | Share |
|---|---|---|
| <$1/sqft (rural acreage) | 6 | 4.3% |
| $1–5/sqft (standard A1) | 64 | 46.0% |
| $5–10/sqft (mid-tier) | 14 | 10.1% |
| $10–17/sqft (transitional) | 25 | 18.0% |
| $17–22/sqft (near-downtown sub-cohort) | 22 | 15.8% |
| $22+/sqft (downtown-core sub-cohort) — subject is here | 8 | 5.8% |
Forty-six percent of the A1 cohort sits at $1–5/sqft of land. The subject is in the top 5.8% — a sub-cohort of eight parcels concentrated on the central downtown blocks. The median of all A1 peers is $4.51 per square foot of lot. The subject is at $24.00. That's a +432% premium over the same-class median, in the same neighborhood code.
If you stop there, the obvious objection is: "the downtown core is just worth more — those parcels have higher market value because of location." That's a fair instinct. So we kept pulling.
The coordinated sub-cohort repricing
We took the eight parcels in the $22+/sqft tier and pulled their land-value history from 2023 and 2024. If the downtown core had been valued at this level for years, that would tell one story. If the entire tier got repriced in a single year, that tells another.
Land-value moves for the $22+/sqft A1 sub-cohort, 2023 → 2024
| Address | 2023 Land | 2024 Land | Jump |
|---|---|---|---|
| Subject (anonymized) | $48,300 | $207,000 | +329% |
| 140 W Renfro St | $92,000 | $276,000 | +200% |
| 140 S Dobson St | $334,541 | $334,541 | 0% |
| 216 S Warren St | $34,500 | $138,000 | +300% |
| 204 S Wilson St | $75,000 | $75,000 | 0% |
| 124 W Eldred St | $42,090 | $168,360 | +300% |
| 132 W Eldred St | $42,090 | $168,360 | +300% |
| 213 S Wilson St | $23,000 | $138,000 | +500% |
| 117 W Bufford St | $33,065 | $158,712 | +380% |
Six out of eight parcels in this tier had their land repriced by 200% to 500% in a single year. Two were already at the high values, suggesting earlier ad-hoc adjustments. None of the eight had their legal classification changed from A1.
This is not a market-driven appreciation curve. It's a CAD action — a deliberate decision to reprice a sub-cohort of parcels in a single valuation cycle. And that decision triggers specific procedural obligations under Texas law that, in this case, the CAD did not appear to fulfill.
What Texas law actually requires
Three statutes are in play.
§41.43(b)(3) — Equal and Uniform
Texas Property Tax Code §41.43(b)(3) entitles a property owner to appraisal at the median value of a reasonable number of comparable properties, appropriately adjusted. The Texas Supreme Court has clarified that "comparable" means comparable in legal class and use — not merely nearby geography [1].
For the subject, the CAD's own records say A1 — Real, Residential, Single Family. The proper comparable set is therefore other A1 parcels in the same neighborhood, regardless of whether the adjacent corner buildings are classified F1 commercial. The median of that comparable set is $4.51/sqft of lot. The CAD applied $24.00/sqft.
§25.19 — Notice of Appraised Value
When a CAD increases a property's appraised value above the prior year's, §25.19 requires written notice to the owner explaining the change, the evidence on which it relies, and the protest deadline [2]. A 329% single-year land-value increase is, by any reasonable reading, the kind of change that triggers heightened notice obligations.
§23.55 — Change of Use Procedure
If a property's valuation methodology is changing because the CAD believes the property has transitioned to a different use category (residential to commercial, agricultural to development), §23.55 specifies the procedural path: formal notice, opportunity to contest, and — if applicable — rollback tax recapture [3].
In the cases we examined, none of these procedures appeared to have been triggered. The CAD applied commercial-equivalent valuation tiers to A1 parcels while keeping the legal classification at A1. That's the procedural gap.
Either the CAD reclassifies the property to a commercial or mixed-use code — which triggers §25.19 notice, §23.55 procedure, and the owner's right to contest the reclassification before it takes effect — or it must value the property using comparables of the same legal class. It cannot apply one class's valuation methodology and another class's procedural treatment.
Why CADs do this
The economic incentive is structural, not malicious. Every two years the Texas Comptroller runs the Property Value Study (PVS) — a state audit that checks whether a CAD's appraised values track local sale prices [4]. If a CAD's values fall below roughly 95% of market, the local school districts get penalized in the state funding formula. School superintendents put pressure on CAD boards. CAD boards put pressure on chief appraisers. Chief appraisers find ways to lift values into compliance.
Downtown cores in fast-growing Texas cities are the easiest target. The market sales there genuinely have appreciated — but they're commercial-use sales, not residential. The CAD has two honest options:
- Reclassify the residentially-classed parcels formally — with notice, with hearings, with rollback obligations. This is procedurally clean but politically expensive.
- Leave them classified as residential and value them at residential medians — which keeps PVS compliance pressure on the school formula, not on individual homeowners.
The path we documented in Burleson is neither of those. It's a third path that takes the upside of option 1 (higher values) while skipping the procedural costs of option 1. That third path is what §41.43(b)(3) is specifically designed to challenge.
What residents get in return
Here's the part that most Texas homeowners never have explained to them: when your assessed value jumps, the additional revenue does not mostly flow into local services proportional to your contribution. The Texas school finance system recaptures most of the local revenue windfall under Chapter 49 of the Texas Education Code, the "Robin Hood" provision [5].
At the county and city level, Senate Bill 2 (passed in 2019) caps non-school taxing units at 3.5% revenue growth without voter approval [6]. So when assessed values jump 50% or more, the tax rates have to come down to comply — and they usually do — but the relief is incomplete and uneven across property owners. The ones whose values jumped the most still pay substantially more, while the ones whose values stayed flat see proportionally lower bills.
Put together, the picture is uncomfortable: an appraisal district with economic motive to value high, a state finance formula that captures most of the windfall, and a homeowner whose protest rights exist on paper but require expertise most people don't have. The 25%-of-savings consultants exist because the market gap is real, but their fee structure means they only chase the biggest cases.
What to do if you see this pattern on your record
Five things to look for in your CAD record:
- Pull your "Notice of Appraised Value" (§25.19) for the tax year in question. If the CAD never sent one — or sent one that doesn't itemize what changed — that's procedural defect #1.
- Look at the land-value line specifically. Not the total appraised value, the LAND line. If it jumped more than ~30% in a single year without any change in lot size or platting, ask the CAD to explain the methodology in writing.
- Compare to other parcels of the same legal class in the same neighborhood. CADs publish this data; you can pull it from their online portal. If your $/sqft of lot is 2× or more the median of your class peers, you have a §41.43(b)(3) equal-and-uniform protest.
- Don't accept "highest and best use" as a complete answer. Highest-and-best-use valuation requires a corresponding formal classification change. The CAD cannot have the valuation upside without the procedural costs.
- The May 15 deadline isn't the only window. Texas §25.25(c) allows correction motions for up to 5 prior tax years when the appraisal record contains an error of inaccuracy or substantial value misstatement.
The wider pattern
We've started seeing similar patterns in several DFW-area appraisal districts. Tarrant CAD's 2024 commercial revaluations, Dallas CAD's approach to mixed-use cores, Collin CAD's handling of legacy small-lot subdivisions — all involve sub-cohort repricing that doesn't always clear the §41.43(b)(3) and §25.19 procedural bars when challenged.
We'll be tracking these as we see them and publishing what we find. If you've spotted a similar pattern on your own property — or a friend's — we'd genuinely like to hear about it.
Think your property fits this pattern?
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Get notified when TaxStand launches in your countyReferences & further reading
- Texas Property Tax Code §41.43(b)(3). For the case-law definition of "comparable," see Harris County Appraisal District v. United Investors Realty Trust, 47 S.W.3d 648 (Tex. App.—Houston [14th Dist.] 2001). statutes.capitol.texas.gov/Docs/TX/htm/TX.41.htm
- Texas Property Tax Code §25.19 — Notice of Appraised Value. statutes.capitol.texas.gov/Docs/TX/htm/TX.25.htm
- Texas Property Tax Code §23.55 — Change of Use of Land. statutes.capitol.texas.gov/Docs/TX/htm/TX.23.htm
- Texas Comptroller, Property Value Study (PVS) and Methods and Assistance Program (MAP) overview. comptroller.texas.gov/taxes/property-tax/pvs/
- Texas Education Code Chapter 49 — Options for Local Revenue Levels in Excess of Entitlement. statutes.capitol.texas.gov/Docs/ED/htm/ED.49.htm
- Senate Bill 2 (86th Texas Legislature, 2019) — Texas Property Tax Reform and Transparency Act. capitol.texas.gov/BillLookup/History.aspx?LegSess=86R&Bill=SB2
- All parcel-level data in this case study is from the Johnson County Appraisal District's public records, pulled May 18, 2026. Property owner is anonymized. The procedural analysis is informational and not legal advice.