How to Defend Your Comps When the Appraiser or ARB Says, "These Aren't Good"

By Harsha N Hegde | Updated: May 22, 2025

Whether you're attending an informal hearing with a CAD appraiser or a formal hearing before the Appraisal Review Board (ARB), you're likely to hear this line: "Your comps are not good." It's a common pushback—often vague, sometimes dismissive. But if you're prepared, you can counter it effectively and assert your legal rights.

Here is how to prepare, what to say, and how to handle the hearing with confidence.

1. Request the CAD’s Evidence in Advance

Before your hearing, make sure to request the CAD's evidence packet.

Under Texas Property Tax Code §41.461, the appraisal district must provide its evidence at least 14 days before your hearing. If you filed your protest online, most CADs will upload the evidence to your online portal automatically.

Carefully review the CAD’s evidence packet—it usually includes their equity and sales grids. As you go through it, ask:

• Are the comps within 1 mile of my property?
• Do they match my lot size and building square footage?
• Are they the same number of stories?
• Are the bed/bath counts comparable?
• Are they close in year built, quality, and desirability?

Use this analysis to identify flaws in the CAD’s evidence—and strengthen your own.

🔍 Important Tip

If any of the CAD’s selected comps have recently received value reductions, bring this up during the hearing. Highlighting reduced comps in their own evidence can undermine their median and strengthen your position. You can cross-check the values mentioned in the CAD's grids with the values shown on their website. You can use our CAD Evidence Review feature to do this automatically for you.

2. How to Respond When They Say "Your Comps Are Not Good"

Whether it's a CAD appraiser or an ARB panel member challenging your evidence, stay calm and use the following counterpoints:

Ask for Specifics

Say: "Can you explain why you believe these comps are invalid? Is it due to location, age, size, or another factor?"

Why it works: Forces them to provide a reason. Many times, they won’t have one.

Emphasize Neighborhood Consistency

Say: "These comps are in the same neighborhood code or market area as my property."

Why it works: Texas Tax Code §42.26(a)(3) allows equity protests using comparable properties in the same neighborhood.

Highlight Inconsistencies in CAD's Own Data

Say: "Some of the comps I’ve used are also in the CAD’s own evidence grid. If they're valid for the CAD, they should be valid for me."

Why it works: Shows that you're using the same methodology as the CAD.

Cite the Law

Say: "Section 42.26(a)(3) gives me the right to argue that my property is not appraised equally with similar properties."

Why it works: You're invoking a legal standard, not just a personal opinion.

Mention Your Adjustments

Say: "I've adjusted for differences in improvement size, year built, and other features to make a fair comparison."

Why it works: Shows that your analysis is reasoned, not random.

3. Highlight Strengths of Your Square Deal Report

If you purchased your report from Square Deal, you already have detailed, well-matched comps at your fingertips. Page 2 of the report has highlights you can point out during your hearing:

• ✅ All comps are in the same neighborhood as the Subject: e.g., Neighborhood Code 7932.04
• ✅ Comps are within ±x years of the Subject's year built
• ✅ All comps are located within x miles of the Subject
• ✅ Living areas are within ±x sqft of the Subject
• ✅ Same construction quality: e.g., all comps rated "Average"
• ✅ Same construction grade: e.g., all comps rated "C+"
• ✅ Similar CDU (Condition, Desirability, Utility): e.g., all comps are rated "Average"

Use this data to back your case when someone tries to discredit your report.

Addressing the “These Are Appraisal Comps” Argument

Sometimes, appraisers or ARB members will dismiss your evidence saying:

“We’re looking for sales comps. These are just appraisal comps.”

This is not a valid reason to dismiss your evidence. If you selected "Unequal Appraisal" as one of your protest reasons when you filed your protest, you are well within your legal rights to present appraisal comps. If the need arises, don't hesitate from quoting the law: Texas Propery Tax Code Section 42.26(a)(3), which is about unequal appraisal. That section allows you to compare your appraised value with the appraised values of similar properties — not sales prices.

So if your comps show other homes like yours are being appraised for less, you’re absolutely within your legal right to bring that forward.

4. Final Tips for Your Hearing

• Stay respectful and firm. Don't let vague objections undermine your case.
• Point out flaws in the CAD’s comps just as they may try to find faults in yours.
• Bring multiple copies of your evidence: 4 sets of documents and at least 2 sets of photos.

Remember:

Neither the appraiser nor the ARB can raise your value during the hearing. So there’s no risk in showing up and making your case. Be prepared, be firm, and stand your ground with logic, evidence, and the law on your side.

About the Author

Harsha N Hegde is the founder of squaredeal.tax, a DIY platform that helps Texas homeowners protest unfair property tax assessments. He has helped thousands of Texas homeowners save money using comps-based evidence and practical guidance.