dissenting. The majority affirms the decision of the State Board of Appraisers on the basis of a statutory argument not raised by the parties before the Board and not argued here. Without briefing or oral argument the majority interprets the statute in question in a manner that ignores its text in favor of a statement by one of its legislative proponents. That interpretation renders 32 V.S.A. § 4404(c) meaningless and the work of the Board of Civil Authority (BCA) insignificant because of the supposedly curative effect of de novo review by the State Board. I believe that the “curative effect” urged by the majority ignores the very essence of § 4404(c) — to encourage clear and candid decisions by BCAs — and undermines the strong sanction of previous-year valuations for failure to comply with its mandates. Finally, the most troublesome flaw in the majority position is that it misconstrues and minimizes the issue of discrimination, which lies at the heart of property tax disputes both as to initial valuation and equalization.
We have steadfastly held that claims raised for the first time on appeal will not be considered by this Court. Varnum v. Varnum, 155 Vt. 376, 382, 586 A.2d 1107, 1110 (1990). We bend the rule “in extreme and unusual circumstances,” id., particularly where “fundamental rights and interests are at stake.” Id. at 383, 586 A.2d at 1111. The issue on which the majority decides the present case was not raised below by defendant Town of Waltham.1 The State Board announced during the hearing that “the'BCA report did not reflect the reasons for the change or the reasons for no change, [and] was without reasons.” It was perhaps understandable that the Town did not contest the Board’s finding that the BCA failed to give reasons, since the Board simultaneously announced that taxpayers had waived their rights under the statute. But the Town was on clear notice *485that taxpayers were challenging the Board’s waiver finding on appeal and nevertheless failed to raise the § 4404(c) issue either at hearing or on appeal. This Court should not do so sua sponte. See Tallarico v. Brett, 137 Vt. 52, 61, 400 A.2d 959, 965 (1979); Keene v. Willis, 128 Vt. 187, 188, 260 A.2d 371, 372 (1969).
A principal reason for not considering issues not presented by the parties at trial or in their briefs is the great risk of deciding important issues without hearing reasoned arguments on both sides of a question, especially a novel question. See Favreau v. Miller, 156 Vt. 222, 233, 591 A.2d 68, 75 (1991) (Dooley, J., dissenting). As the majority notes, we have not had occasion to consider § 4404(c) since it was amended following Hojaboom v. Town of Swanton, 141 Vt. 43, 442 A.2d 1301 (1982), and sound appellate practice should encourage us to wait until the issue is presented before we venture to judgment. I would await a case in which the effect of the legislative changes is briefed and argued.
I would distinguish what the majority has done in this case from the numerous instances in which we affirm a trial court ruling, even though the reasoning of the trial court or administrative body is wrong. In such cases the relevant legal issue has been preserved. It is only the trial court’s rationale for resolving the issue that we differ with in this class of cases. For example, in Vermont State Colleges Faculty Federation v. Vermont State Colleges, 151 Vt. 457, 463, 561 A.2d 417, 421 (1989), the Court' upheld the Labor Relations Board’s affirmance of Vermont Technical College’s (VTC’s) denial of funds for a sabbatical. The Board had stated as its grounds the incorrect conclusion that no evidence had been presented of violations of two articles of the labor agreement. The Court instead interpreted the agreement, which was before it, as allowing VTC to grant prospective-only sabbaticals. In Weyerhaeuser Co. v. Town of Hancock, 151 Vt. 279, 283, 559 A.2d 158, 161 (1989), the issue was whether certain of the taxpayer’s machines were taxable as real estate. The Board, erroneously applying 32 V.S.A. § 3618, rather than § 3602, concluded that they were. We affirmed because the result would have been the same under § 3602. Again, the legal basis for our decision was properly before us.
The majority asserts that “[t]he requirements of § 4404(c) are technical; the taxpayers suffered no prejudice from any *486breach of them. The taxpayers’ rights are fully protected by the de novo appeal to the Board.” If the Legislature intended the Board to cure all “technical” omissions by BCAs, there would be no need for § 4404(c). It is clear in the context of this statute and others governing the conduct of municipal bodies that the intention of the Legislature is to encourage thorough and timely review for all taxpayers, not only for those few who appeal to the Board. 32 Y.S.A. § 4404(c) imposes strictures both as to the time of decision and the inclusion of reasons. What is, or is not, substantial compliance with the statute is a question the Board is in a better position to answer than this Court. The tax appeal process before the BCA and the State Board is relatively informal and often conducted without the presence of attorneys for either the taxpayers or the town. This Court has in recent years shown deference to the Board in tax decisions. Sondergeld v. Town of Hubbardton, 150 Vt. 565, 571, 556 A.2d 64, 68 (1988). The Board is familiar with the quality of the “reasons” supplied by BCAs in cases like the present, since it deals with vast numbers of tax appeals, only a few of which are appealed and even fewer of which raise the question of how well a BCA has performed its duties.2 The majority’s decision, while pur*487porting to defer to a lay board (the BCA), questions the judgment and discretion of the State Board.
The majority states that the taxpayers’ “sole claim” to the BCA was that they had been discriminated against, compared to certain other named landowners. The majority concludes that the BCA’s explanation that the assessment “is similar to assessments of surrounding land” constituted “a sufficient explanation to comply with the statute.” On the contrary, under either the former version of § 4404(c) or the present one, those words are merely tautological and provided no explanation whatever. A claim of discrimination by taxpayers always amounts to an assertion that the assessment is dissimilar (or disproportionate) to assessments of surrounding, or otherwise comparable, property, either because of an inconsistent initial valuation or because of misapplication of the municipality’s equalization ratio. A contrary assertion does not provide a “reason” for the BCA’s decision.
Discrimination is not the most important issue; it is the only issue, as our very substantial body of property tax decisions has shown over the years. The guiding statute, 32 V.S.A. § 4467, specifically refers to Chapter I, Article 9 of the Vermont Constitution and the Fourteenth Amendment to the United States Constitution, because of the role of those provisions in combat-ting state-sponsored discrimination of all kinds. See, e.g., Alexander v. Town of Barton, 152 Vt. 148, 158-60, 565 A.2d 1294, 1300-01 (1989). This Court now holds that the BCA meets the standard of the statute when it gives no more answer to taxpayers’ claim that an assessment is dissimilar to assessments of surrounding land than the response, “the assessment is similar to assessments of surrounding land” — in other words, “You’re wrong.”3 In Saufroy v. Town of Danville, 148 Vt. 624, 625, 538 *488A.2d 168, 169 (1987), we condemned strikingly similar language used by the State Board in its decision in that case based, in part, on the Board’s skimpy explanation that a comparable property offered by the town “defines the general range of the fair market value of the Saufroys’ property.” We said:
Beyond a recognition in the findings that there were very significant differences between taxpayers’ property and the comparable property, the Board offers no explanation how these differences cancel out so that the fair market values are identical. We are left to speculate on how the Board reached its conclusion on fair market value.
Id. at 625-26, 538 A.2d at 169. See also Roy v. Town of Barnet, 147 Vt. 551, 551-52, 522 A.2d 225, 226 (1986) (State Board has duty to make clear statements so that this Court and the parties will be able to determine how decision was reached); Schweizer v. Town of Pomfret, 134 Vt. 436, 437, 365 A.2d 134, 135 (1976) (Board has duty to make specific findings; to merely state that it “checked” the comparable properties constitutes reversible error). While the BCA is not to be held to the same standard of detail as the State Board, § 4404(c) requires an explanation of how the result was reached. Here, none was given.
I am authorized to say that Justice Gibson joins in this dissent.
The majority states that “the taxpayers fully briefed the issue,” but that is not the case. There is no mention anywhere in taxpayers’ brief of the grounds on which the majority bases its decision. Taxpayers argued simply that the BCA “failed to give adequate reasons for its decision on the Harrises’ appeal,” which argument would have prevailed, according to the majority, but for § 4404(c) “as it is currently constructed.” The majority’s rationale is based entirely on the proposition that the amendment to the statute altered the duty of the BCA in a manner that affected the outcome of this case — a proposition that the Town did not raise and the taxpayers, contrary to the majority’s statement, had no chance to refute.
The majority states that “[t]he Board’s determination is clearly based ... on the preamendment language as applied in Punderson.” The Board chairman stated that “the BCA report did not reflect the reasons for the change or the reasons for no change, [and] was without reasons.” Only the amended version of § 4404(e) speaks of “reasons.” The earlier version requires “findings in the premises.” The Board’s written decision states, “Subsection 4404(c) of VSA Title 32 specifies that the Board of civil Authority notice of decision be ‘with reasons.’” It does not cite or rely on any preamendment cases.
More importantly, since no reasons whatever were offered, the Board’s ruling on the BCA should stand under either version of the statute, though it seems clear that it was relying upon § 4404(c), as amended. The majority rescues the Town’s position by demeaning its capacity: “We doubt that a town of 454 residents, . . . whose volunteer citizen board of civil authority hears a property tax appeal and files its decision within an hour of the start of the hearing, will ever provide a detailed explanation of its reasoning to meet the dissent’s standards.” It is the Legislature, not this Court, that has directed the Board of Civil Authority to give reasons, and a sociological exploration of the BCA’s role and abilities is not within our charge.
I do not think, as the majority suggests, that the Legislature mandated that the BCA “provide a detailed explanation.” It required only “reasons,” *487and gave the State Board the power to judge whether reasons have been provided. I would simply hold what is clear — that the BCA did not give reasons, detailed or otherwise, and that the Board did not abuse its discretion in saying so.
Just as important as this decision itself will be its effect on citizens and citizen boards trying to do their best in an area of the law that is inherently difficult, and especially so with statutes that would benefit from legislative *488review and clarification. Our point is not, as characterized by the majority, that § 4404(c) requires “not only that the BCA state its reasons but also that it have good reasons.” We emphasize that the BCA gave no reasons — none, and for this Court to suggest that it did so will surely send all the wrong signals to a wide range of administrative boards from whom we do not demand eloquence or detail, but from whom we have long required reasons on behalf of the people they serve. This case is not about the difference between the standards applicable to the BCA and the State Board; it is about construing a mandate that a Vermont state board say something, as allowing the board to say nothing. We have set a standard that no board can now possibly fail to meet, but at some cost to the people they serve.