¶ 31. concurring and dissenting. This high-value complex case was tried by lawyers for the taxpayer and the Town to an administrative hearing officer appointed by the Director of Property Valuation and Review. The fundamental deficiency in the decision is that it consists only of five pages of recitations of the evidence, followed by a short conclusory statement that the hearing officer, called the state appraiser, found the Town’s expert witness more persuasive than the experts presented by the taxpayer. Its conclusion was “I find the appellant was not able to overcome the Town’s market and assessed value and it shall be set in the 2011 grand list at $92,023,700.”
*597¶ 32. We have repeatedly held, and particularly in property tax appeals, that recitations of the evidence are not findings of fact, and that findings of fact are required.5 See Beach Props., Inc. v. Town of Ferrisburg, 161 Vt. 368, 371, 640 A.2d 50, 51 (1994); Saufroy v. Town of Danville, 148 Vt. 624, 625, 538 A.2d 168, 168-69 (1987). Where there is conflicting evidence, the hearing officer “must state clearly what evidence it credits and why, so that the parties and this Court will know how the decision was reached.” Beach Props., Inc., 161 Vt. at 371, 640 A.2d at 51. A valuation decision must be supported by adequate findings, or it will not be affirmed. Id.
¶ 33. Ironically, one of the main arguments made in the previous case about the valuation of this property, Vermont Electric Power Co. v. Town of Vernon, was that the hearing officer’s decision failed to contain clear findings and an explanation of how the decision was reached. 174 Vt. 471, 807 A.2d 430 (2002) (mem.). In part because the Town squarely presented the dispute as turning on whether to adopt the Iowa Curve for calculating depreciation and the life expectancy of the property, and because the primary deficiency actually helped the Town, we found we did not have “to speculate on how the conclusion was reached.” Id. at 474, 807 A.2d at 435.
¶ 34. This case presents a more extreme example of the deficiencies in the earlier administrative decision. There are no valid findings of fact, and we do have to speculate on how the hearing officer reached his decision on the elements of the value of the property and, therefore, on the property as a whole. It is a poor quality decision that does not meet the minimum standards we have announced in many decisions.6 The parties filed extensive requests for findings, which the hearing officer could easily have *598used to make findings of fact demonstrating the rationale for the decision. Instead, those requests for findings were largely wasted.
¶ 35. I do not believe we can uphold any of the decision, including the rejection of the use of the Iowa Curve. Although I agree with the majority that taxpayer failed to preserve its claim preclusion argument, I do not agree that we can affirm the hearing officer’s decision to use straight-line depreciation without adequate findings. To summarize, I agree with sections I, III, and IV of the majority decision. I also agree with section II, but do not believe it goes far enough.
¶ 36. This case raises a strong question as to whether the administrative process is up to the decisionmaking that is called for. At one point in the past, we reversed and remanded virtually every decision that came from the administrative hearing authority for property tax appeals, usually because of inadequate findings. See, e.g., Spencer v. Town of Danville, 148 Vt. 626, 538 A.2d 169 (1987); Saufroy, 148 Vt. 624, 538 A.2d 168; Gouin v. Town of Halifax, 148 Vt. 524, 535 A.2d 788 (1987); Adams v. Town of West Haven, 147 Vt. 618, 523 A.2d 1244 (1987); Roy v. Town of Barnet, 147 Vt. 551, 522 A.2d 225 (1986). Over time, the appeals process was reformed to the single hearing officer model we now have, and the quality of the adjudication improved so that most administrative decisions are affirmed by this Court. Nevertheless, the quality of _ adjudication of cases involving high-value commercial and industrial properties has continued to raise concerns. Examples are this case, the previous case involving the same property, and the Beach Properties case, 161 Vt. 368, 640 A.2d 50, which involved a large resort.
¶ 37. The Legislature has offered the appealing party a choice in property tax cases: to appeal to either (a) the Director of Property Valuation and Review, or (b) the superior court. 32 V.S.A. § 4461(a). The taxpayer chose the administrative process — I suspect because it thought that the hearing officer would just rely upon the 2002 decision.
¶ 38. In my opinion, a case of this size and complexity, where each party is fully represented by counsel, belongs in superior court where the judge is more used to evaluating expert testimony of this intricacy and is skilled in producing a good quality and complete decision. The Legislature should reconsider the unfettered choice the current statute allows and restrict larger cases, like this, to court appeals. While I would expect the administrative *599appeal route to be initially less expensive and more efficient, it is not ultimately so if the chance of reversal on appeal is very high. In any event, the amount in controversy is sufficiently high to warrant a higher-cost adjudication process.
Taxpayer has also relied on 3 V.S.A. § 812(a), which requires “findings of fact and conclusions of law, separately stated.”
Because the hearing officer concluded that taxpayer “was not able to overcome the Town’s market and assessed value,” taxpayer has argued that the decision was reached improperly based on a presumption. The improper use of the presumption of validity of the Town valuation has been another source of frequent reversals of administrative valuation decisions. E.g., Rutland Country Club v. City of Rutland, 140 Vt. 142, 146, 436 A.2d 730, 732 (1981). In this case, however, the statement to which the taxpayer points is vague and does not necessarily invoke a presumption. While it would have been preferable for the hearing officer to state that taxpayer failed to meet its burden of persuasion, I cannot say that the hearing officer improperly used a presumption.