The strongest DIY argument in a Texas protest: your value versus the median of comparable homes

Texas Tax Code §41.43(b)(3) says your protest is decided in your favor unless HCAD proves your appraised value is at or below the median of a reasonable number of comparable properties. Here is exactly how to build that case yourself, free, straight from HCAD's own records.

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Every Texas property tax protest can argue two different things: that your home's market value is too high, or that your home is unequally appraised compared with similar homes nearby — commonly called the "equal and uniform" argument. For most Harris County homeowners, equal-and-uniform is the stronger, easier case to build yourself, because it does not depend on knowing what your house would sell for. It depends on comparing your HCAD-assigned value against other HCAD-assigned values — numbers that are public, free, and already sitting in HCAD's own database. This page walks through exactly how that argument works and how to build it.

The one-line version: under Tax Code §41.43(b)(3), an unequal-appraisal protest is decided in your favor unless HCAD proves your appraised value is at or below the median appraised value of a reasonable number of comparable properties, appropriately adjusted. Pull 5–10 similar homes from search.hcad.org, compare appraised value per square foot, find the median, adjust for real differences, and multiply by your own square footage. If your number is lower than what HCAD has you at, that gap is your case.

Last updated: July 26, 2026 · Harris County, Texas.

For a sense of the spread you are working inside, counting HCAD's own public appraisal roll: the median Harris County single-family home is appraised at $111.97 per square foot, and the middle 80% runs from $84.36 to $184.70 (1,138,932 homes with a recorded building area). A county-wide median is not a comp and will not win a hearing — §41.43(b)(3) compares you to a reasonable number of comparable properties — but it shows how much of that spread is age and condition rather than value. The same roll is where our Harris County exemption-gap findings come from — 328,310 homes (28.4%) with no homestead exemption on record, which is never evidence that anyone is overpaying: rentals, second homes, estate-held property and recent purchases legitimately have none.

Two companion pages go a level deeper into the mechanics: how HCAD decides what your home is worth explains where the district's number comes from and what the homestead cap does to it, and how we choose your comparable homes sets out every filter we apply, in full.

1. What "equal and uniform" actually means (§41.43(b))

Texas law does not just require your home to be appraised at market value — it also requires appraisal to be equal and uniform with comparable properties. Tax Code §41.43(b) states plainly: "A protest on the ground of unequal appraisal of property shall be determined in favor of the protesting party unless the appraisal district establishes" one of three things. In practice, that flips the burden onto HCAD once you have made a credible comparison. The three ways HCAD can rebut your protest are:

(b)(3) is the one most homeowners use, because it compares dollar values directly instead of appraisal ratios that require district-wide sales-ratio data most homeowners cannot easily access. If HCAD cannot show your value is at or below that adjusted median, the statute says the protest goes in your favor.

2. Why Zillow is weak evidence here — and HCAD's own numbers are strong

Texas is a non-disclosure state: unlike most states, actual home sale prices are not required to be recorded anywhere public. That means Zillow's "Zestimate," Redfin's estimate, and similar tools are statistical guesses built without access to real local sale prices — HCAD is not required to give them any weight, and appraisers routinely dismiss them at hearings.

What the statute points you toward instead is HCAD's own appraised values of comparable properties — numbers the district itself assigned, sitting in its own public records. Those are far harder for an appraiser to argue against, because disputing them means disputing HCAD's own work on another property, not a third-party estimate. This is also why the site's $39 protest kit builds its evidence packet exclusively from HCAD's own records, not sale-price estimates.

HCAD's own numbers are the evidence the law points you to. Here's how to pull them yourself.
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3. How to pick comparable properties

"Comparable" has a specific meaning under the statute — §41.43(b)(2) and (b)(3) both describe comparables as properties "similarly situated to, or of the same general kind or character" as yours, appropriately adjusted for differences. In practice, look for:

4. How to compute the median and adjust it

Once you have your list of comparables, the math is straightforward:

  1. Pull each comparable's HCAD-appraised value and square footage from search.hcad.org, and divide value by square footage to get a price per square foot for each one.
  2. Sort the per-square-foot values from lowest to highest.
  3. Take the median — the middle number in an odd-numbered list, or the average of the two middle numbers in an even-numbered list.
  4. Adjust for real differences that the raw per-square-foot number does not capture — a comparable with a pool, an extra garage bay, or a recent full renovation may need adjusting up; storm damage, deferred maintenance, or a busy-street lot may need adjusting down. The statute's "appropriately adjusted" language exists precisely so raw averages do not have to be treated as exact.
  5. Multiply the adjusted median per-square-foot figure by your own home's square footage to get your comparable-based value.

If that number is meaningfully below what HCAD has assigned your home, you have the core of an equal-and-uniform protest. Bring the comparables list, the math, and copies of each property's HCAD detail page as your evidence.

A short worked example

ComparableHCAD valueSq ft$/sq ft
Comp A$285,0001,900$150.00
Comp B$312,0002,050$152.20
Comp C$298,0002,000$149.00
Comp D$330,0002,100$157.14
Comp E$276,0001,880$146.81

Sorted: $146.81, $149.00, $150.00, $152.20, $157.14 — the median is $150.00/sq ft. If your own home is 2,000 sq ft, the comparable-based value is roughly $300,000. If HCAD has your home appraised at $340,000, that $40,000 gap — adjusted for any real differences between your home and the comps — is the basis of your protest.

5. Where to get the data — free, from HCAD itself

search.hcad.org is HCAD's own public property search, and it is free to use. Look up your own account first to see your neighborhood code, square footage, condition rating, and current appraised value. Then search nearby properties sharing your neighborhood code to build your comparables list. Every figure you pull this way is HCAD's own public record — exactly the kind of evidence §41.43(c) describes when it says evidence "includes the data, schedules, formulas, or other information used to establish the matter at issue."

6. Presenting the evidence — iFile, informal review, and the ARB

Once your protest is filed (see our full protest guide for the three ways to file), the same comparables packet works at every stage: as an attachment when you protest online through iFile, as the basis for an informal settlement offer, and as your evidence at a formal Appraisal Review Board hearing. Our ARB hearing guide covers what to expect in the room and how HCAD's own evidence-exchange deadlines work.

This is exactly the packet our $39 kit builds for you — from HCAD's own records, adjusted, and attached to your form.
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7. Being honest: our $39 kit automates this exact process

Everything above can be done for free with a spreadsheet and search.hcad.org — nothing on this page requires paying us anything. Our $39 protest kit automates the same process: it pulls comparable properties from HCAD's own records for your specific home, calculates the adjusted median, and fills out Form 50-132 with the evidence attached, so you are not spending an evening building spreadsheets by hand. It is a convenience, not a requirement — you can do everything on this page yourself, for free, using only HCAD's own public data.

The honest limits

Read this part. We are not attorneys and not tax agents. HCAD and the Appraisal Review Board decide every protest — comparable-property evidence strengthens your case, but it does not guarantee a specific outcome.

Who to call, and where to send it

What you needWhere
Free HCAD property search — pull your own compssearch.hcad.org
File your protest online (Form 50-132)owners.hcad.org
Mail or drop off a protestHarris Central Appraisal District, 13013 Northwest Freeway, Houston, TX 77040-6305
Full protest guide (three ways to file, deadlines)Our free protest guide
ARB hearing guide (how to present this evidence in the room)Our free ARB hearing guide
QuestionsHCAD Telephone Information Center — (713) 957-7800, 8:00–5:00 Monday–Friday
The statute itselfTax Code §41.43 · Comptroller — Property Tax Protests

Common questions

Do I need to prove my home's market value, or is equal-and-uniform enough on its own?

You can protest on either ground, or both, on the same Form 50-132. Equal-and-uniform (§41.43(b)) does not require you to prove what your home would sell for — only that similar homes are appraised lower. Most DIY protesters lead with equal-and-uniform because the evidence is free and public.

How many comparable properties do I need?

The statute says "a reasonable number" without a fixed count. Five to ten well-chosen comparables is a common, defensible range. One or two is thin; twenty scattered, poorly-matched properties is not stronger than ten well-matched ones.

Can HCAD just reject my comps?

An appraiser can dispute whether your chosen properties are genuinely comparable, or argue your adjustments are wrong — that is part of a normal hearing. That is also why choosing honestly similar properties, adjusted honestly, matters more than choosing the lowest numbers you can find.

Is this the same evidence a paid tax firm would use?

Yes. Paid firms build the same kind of comparable-property packet from the same public HCAD records — the difference is they charge a percentage of your savings every year to do it. Nothing about the evidence itself requires a firm.

Does equal-and-uniform evidence work for the ARB hearing too, not just iFile or informal review?

Yes — the same comparables packet is your evidence at every stage: attached to an iFile protest, the basis for an informal settlement discussion, and your exhibit at a formal ARB hearing if it goes that far.

Pull your comps, find the median, and see the gap for yourself — free.
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Last updated: July 26, 2026. Sources: Texas Tax Code §41.43, Protest of Determination of Value or Inequality of Appraisal; Harris Central Appraisal District, Property Search (search.hcad.org) and Protests and Corrections; Texas Comptroller of Public Accounts, Property Tax Protests and Appeals. This page is general information for Harris County homeowners, not legal or tax advice. Verify current rules with HCAD or the Comptroller before you file.

Terms explained

What “per square foot” means

Take what the district says a home is worth and divide it by the home's heated living area. That is its value per square foot — the one number that lets you compare houses of different sizes.

Worked example. 9429 Pembrook St has 1,097 square feet of living area and an appraised value of $116,588. $116,588 ÷ 1,097 = $106.28 per square foot.

Heated living area is the measure, not the lot and not the garage. A bigger house will almost always have a bigger total value; per square foot is how you tell whether it is priced differently from its neighbours.

What a “median” is, and why not an average

Line every comparable home up in order, cheapest to dearest, and the median is the one in the middle. It is not the average.

Worked example. For 9429 Pembrook St the tool finds 30 comparable homes. Their median is $70.35 per square foot. Their average is $91.24 — about 30% higher, because one home in the set, 9401 Sundown Dr, is appraised at $270.86 per square foot and drags the average up on its own.

That is why the median is the one that counts. One unusual house barely moves it, and the law names the median specifically: a protest on equal and uniform grounds turns on the median appraised value of comparable properties (Texas Tax Code §41.43(b)(3)).

What “equal and uniform” means

There are two ways to argue a value is wrong. The first is that the home simply is not worth that much. The second — equal and uniform — is that whatever it is worth, it has been appraised higher than comparable homes around it. The second one does not require you to prove what your house would sell for.

The statute sets the test: your value should be “equal to or less than the median appraised value of a reasonable number of comparable properties appropriately adjusted” (§41.43(b)(3)).

Worked example. 9429 Pembrook St is appraised at $116,588. The median appraised value of its 30 comparable homes is $82,294. That difference is the whole argument — and it is made from the district's own published records, not from an opinion about the house.

⚠ “Appropriately adjusted” is doing real work in that sentence. Comparable homes are rarely identical, and a difference in size, age or condition has to be accounted for rather than ignored. The kit files on both grounds, so a case that fails one can still be heard on the other.

What a “neighbourhood code” is

HCAD divides the county into its own valuation areas and gives each one a neighbourhood code. It is the district's grouping, not a subdivision name and not a ZIP code, and it is the first filter on which homes count as comparable to yours.

Worked example. 9429 Pembrook St sits in neighbourhood code 1160.01, which holds 294 homes. Harris County has 5,887 of these codes in all.

Comparables are then narrowed inside that code by size and age — for this home, 944 to 1,278 square feet and built between 1945 and 1966. Sales evidence for a home like this may reach back 36 months (§23.013(b-1)), which is the window the law allows for residential property in a county this size.

Two houses on the same street can sit in different codes, and that is not an error. It is why comparables are chosen by the district's own grouping rather than by how close the houses look on a map.