Assessing the Facts

March 21, 2024

Sheds – portable, on skids, no utility service, is it assessed or not? This is a question that sounds pretty simple, but guess what? It’s not. I would encourage my fellow township assessors to ask your supervisor of assessments, how should you be assessing sheds in your county?  Are they assessing according to a size minimum? One of the cases I read about has a size requirement of 10x16 or larger. But what if you have a shed that is smaller? Is the building classified and assessed as real property?

In the past, I did not assess sheds that are on skids because they are portable, and the appellant would win a complaint if it ended up at PTAB (Property Tax Appeal Board). WRONG! I learned last fall there have been assessment appeal cases saying that sheds are real property, which are subject to ad valorem taxation (assessed according to value). Boy, do I have my work cut out for me, changing all those “sheds” from NA (not assessed) to being assessed.

What does Illinois statute say?

(35 ILCS 200/1-130)
Sec. 1-130. Property; real property; real estate; land; tract; lot.

  1. The land itself, with all things contained therein, and also all buildings, structures and improvements, and other permanent fixtures thereon, including all oil, gas, coal, and other minerals in the land, and the right to remove oil, gas and other minerals, excluding coal, from the land, and all rights and privileges belonging or pertaining thereto, except where otherwise specified by this Code. Not included therein are low-income housing tax credits authorized by Section 42 of the Internal Revenue Code, 26 U.S.C. 42.

A structure has been defined in the broad sense as any construction or piece of work composed of parts joined together in some definite manner. A building has been defined as a fabric, structure, or edifice, such as a house, church, shop, or the like, designed for the habitation of man or animals or for the shelter of property.

In a 2013 PTAB decision concerning the assessment of a shed in Monroe County, PTAB referenced both Ayrshire Coal Company v. Property Tax Appeal Board, 19 Ill.App.3d 41 (3rd Dist. 1974) and In re Hutchens, 34 Ill.App.3d 1039 (4th Dist. 1976) when they found “the shed is real property and may be assessed as such regardless of its foundation.” (2013 Synopsis of Representative Cases Decided by the Board – Residential Chapter, page R-20)

Wow, don’t we use buildings “for the shelter of property” for all types of things?  Lawn mower, garden tools, hoses, trash, outdoor decorations – anything you’re not leaving out for the weather elements to affect them?  Now, that it’s stated that way – isn’t it like may a small garage?

Like I said – check with your supervisor of assessments first and get busy, if you’re not assessing the sheds already.


Deb Lane, CIAO-I, is a multiple township assessor in LaSalle County serving Meriden, Ophir, and Troy Grove Townships.

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