Bainbridge Limited Lp v. Dekalb County Tax Assessors

CourtCourt of Appeals of Georgia
DecidedFebruary 15, 2022
DocketA21A1808
StatusPublished

This text of Bainbridge Limited Lp v. Dekalb County Tax Assessors (Bainbridge Limited Lp v. Dekalb County Tax Assessors) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bainbridge Limited Lp v. Dekalb County Tax Assessors, (Ga. Ct. App. 2022).

Opinion

SECOND DIVISION MILLER, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

February 15, 2022

In the Court of Appeals of Georgia A21A1808. BAINBRIDGE LTD., L.P. v. DEKALB COUNTY TAX ASSESSORS.

MILLER, Presiding Judge.

In this dispute between Bainbridge Limited L.P. (“Bainbridge”) and the

DeKalb County Tax Assessors (“the County”) concerning the amount of ad valorem

tax of a rent-restricted apartment complex, Bainbridge appeals from the trial court’s

final order declaring the fair market value of the apartment complex for the 2018 tax

year. On appeal, Bainbridge argues that (1) the County’s witnesses failed to apply the

negative impact of the restrictive covenants and higher operating costs of the

apartment complex in its fair market value analysis; (2) the County’s witnesses failed

to make a deduction for economic obsolescence in its fair market value analysis; (3)

the trial court erred by denying its motion in limine to exclude the testimony of one of the County’s witnesses; and (4) the trial court erred by denying its request for

attorney fees under OCGA § 48-5-311. For the reasons that follow, we affirm in part,

vacate in part, and remand this case for further proceedings.

“On appeal from a superior court [in a tax exemption dispute], this Court

accepts the superior court’s findings of fact unless clearly erroneous but applies a de

novo standard of review to the court’s application of the law to those facts as well as

to its legal conclusions.” (Citation omitted.) Cherokee County Bd. of Tax Assessors

v. Mason, 340 Ga. App. 889, 890 (798 SE2d 32) (2017).

The record shows that Bainbridge owns Granite Crossing Apartments (“Granite

Crossing”), which is located in Lithonia, Georgia. The construction of Granite

Crossing was partially financed with low-income housing tax credits (“LIHTC”)

awarded to it by the Georgia Housing and Finance Authority, and in exchange for the

tax credits, 74 units at Granite Crossing were reserved for low-income tenants who

pay rent below the market rates. Construction on Granite Crossing began in 2017 and

was completed after January 1, 2018. Granite Crossing’s assessment for the 2018 tax

year was $11,801,800. Bainbridge appealed the assessment to a hearing officer, who

determined that the property’s fair market value was $10,707,500. Bainbridge then

2 appealed the hearing officer’s decision to the DeKalb County Superior Court, and the

superior court set the matter for a bench trial.

At trial, Calvin Hicks, the chief appraiser for DeKalb County, testified that he

relies upon OCGA § 48-5-2 and various administrative rules in determining a

property’s fair market value. Specifically, he noted that Ga. Comp. R. & Regs. § 560-

11-10-.09 required appraisers to consider various approaches when appraising real

property, including the income approach and the cost approach, and he stated that the

particular approach employed would depend on the availability of reliable data and

the type of property being appraised. He explained that, for the income approach, an

assessor would need properties with comparable market rents and expenses and that

it may be “questionable” to use the income approach to assess a property if that

information were not available. According to Hicks, the cost approach is the best

approach to use to assess a low-income housing tax credit property because it is the

only approach with the necessary available information to render an opinion of the

property’s value. As to the factors listed in OCGA § 48-5-2 which assessors use to

assess a property, Hicks testified that he requires his assessors to consider each factor

in the statute in determining which approach to use and whether each factor applies

in assessing a property. As to Granite Crossing, Hicks testified that he did not believe

3 that the factors listed in OCGA § 48-5-2 (3) (B) (vi), rent limitations and higher

operating costs, applied when using the cost approach. He also testified that rent

restrictions and higher operating costs would not constitute economic obsolescence

because the arrangement regarding restricted rent is a matter of contract and is within

the owner’s control.

Geoffrey Johnson,1 the commercial appraiser supervisor for the DeKalb County

Tax Assessor’s Office, conducted an appraisal of Granite Crossing using the cost

approach. According to Johnson, most of the reliable data supported the use of the

cost approach to determine Granite Crossing’s fair market value. Regarding the

factors listed in OCGA § 48-5-2, Johnson testified that he considered each criteria to

determine if each was relevant in determining the fair market value and that not all

of the factors were relevant. Specifically, he considered rent limitations and higher

operating costs resulting from regulatory requirements imposed on the property, and

he determined that these two factors were not relevant in assessing Granite Crossing’s

fair market value because there was no line item for using those factors under the cost

approach. Johnson described economic obsolescence as negative influences on a

1 Prior to trial, Bainbridge moved to exclude Johnson’s testimony, which the trial court denied.

4 property that are external to the property and beyond the control of the property

owner. Johnson testified that rent restrictions and higher operating costs for low

income housing tax credit properties do not constitute economic obsolescence under

the cost approach because those factors are not external to a decision made by the

parties or the property owner, and in this case, Bainbridge received something in

return for its agreement to reduce the rental rates which was why he did not have a

line item for economic obsolescence. In Johnson’s opinion, Granite Crossing’s fair

market value was $14,226,785. Johnson testified that he did not use the income

approach because Granite Crossing was still under construction as of January 1, 2018,

and that the income approach is not the best approach to use for a property still under

construction because there is very little reliable data available to develop an accurate

valuation of the property.

Bainbridge presented testimony from Glen Bamberger, the chief financial

officer for Wendover Housing, who prepared the application for Bainbridge’s funding

in 2015. Bamberger acknowledged that Granite Crossing was not issued a certificate

of occupancy until February 1, 2018. Bamberger testified that, in his opinion, Granite

Crossing’s fair market value was $1,000,000 under the income approach.

5 Bainbridge also presented testimony from Brian Walsh, an employee of the

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Cherokee County Board of Tax Assessors v. Mason
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Bainbridge Limited Lp v. Dekalb County Tax Assessors, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bainbridge-limited-lp-v-dekalb-county-tax-assessors-gactapp-2022.