Dekalb County Board of Tax Assessors v. Wrh Aztec, Lllp

CourtCourt of Appeals of Georgia
DecidedOctober 30, 2019
DocketA19A1618
StatusPublished

This text of Dekalb County Board of Tax Assessors v. Wrh Aztec, Lllp (Dekalb County Board of Tax Assessors v. Wrh Aztec, Lllp) 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
Dekalb County Board of Tax Assessors v. Wrh Aztec, Lllp, (Ga. Ct. App. 2019).

Opinion

THIRD DIVISION DILLARD, P. J., GOBEIL and HODGES, 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. http://www.gaappeals.us/rules

October 30, 2019

In the Court of Appeals of Georgia A19A1541. DEKALB COUNTY BOARD OF TAX ASSESSORS GO-020 v. CWS SGARR BROOKHAVEN, LLC. A19A1618. DEKALB COUNTY BOARD OF TAX ASESSORS v. GO-060 WRH AZTEC, LLLP.

GOBEIL, Judge.

In these appeals, which we have consolidated, the DeKalb County Board of

Tax Assessors (the “Board”) challenges the Superior Court of DeKalb County’s grant

of the taxpayers’ respective motions for summary judgment. The Board contends that

the trial court erred in granting summary judgment in favor of the taxpayers because

a statutory exception allowed the Board to reassess the properties in question based

on a significant increase in the sales price of similar properties in the same

neighborhood. The Board further asserts that the trial court’s interpretation of the

statutory exception at issue will force the Board to violate constitutional and legislative mandates requiring that all comparable properties be assessed uniformly,

accurately, and at fair market value. For reasons explained more fully below, we find

no error and affirm in both cases.

Summary judgment is appropriate when no genuine issues of material fact

remain and the movant is entitled to judgment as a matter of law. OCGA § 9-11-56

(c). We review a trial court’s grant of summary judgment de novo, construing the

record and all reasonable inferences in favor of the nonmoving party. Smith v. Found,

343 Ga. App. 816, 817 (806 SE2d 287) (2017).

A19A1541

The facts relevant to these appeals are undisputed and, in Case No. A19A1541,

show that CWS owns a garden-style apartment complex1 known as The Marq at

Brookhaven. CWS’s property is located in neighborhood 7051 of DeKalb County,

was constructed in 1998, and consists of 480 “Class B” apartments.2 For the 2016 tax

year, the Board assessed the property at a value of $57,903,500. CWS appealed that

1 Garden-style apartments are defined as including buildings that are no more than three stories tall. 2 For tax purposes, the Board classifies all apartments into Classes A, B, C, or D, with Class A apartments commanding the highest rents and Class D apartments commanding the lowest rents.

2 assessment to the DeKalb County Board of Equalization (“BOE”). The BOE affirmed

the Board’s assessment and set the property’s value at $57,903,500. CWS did not

appeal the BOE’s decision to the superior court, and it paid taxes on the assessed

value.

In 2017, the Board conducted an analysis of the Class B apartment complexes

that sold in neighborhood 7051 during the 2016 calendar year. According to the

Board, that analysis showed that other properties of the same type and class as CWS’s

property “had experienced a significant increase in the median sales price since

January 1, 2016, as compared to earlier years.” Based on the 2016 sales analysis, the

Board concluded that the CWS’s property had been undervalued.3

As part of the revaluation process, the Board sent a commercial property

appraiser to conduct a site visit of the property. Following that visit, the appraiser

recommended a significant increase in the property’s assessed value based on “an

occurrence of other material factors substantially affecting the [fair market value]

within the property’s market area including but not limited to . . . market conditions.”

Accordingly, for the 2017 tax year, the Board assessed the property at $69,573,371.

3 Additionally, based on sales closing after January 1, 2016, the Board decided that it needed to re-value all of the 402 garden-style apartment properties located in DeKalb.

3 CWS appealed that assessment, and the BOE affirmed the Board’s valuation. CWS

then appealed that decision to the superior court.

A19A1618

Similarly, the record in Case No. A19A1618 shows that Aztec owns four

parcels of commercial real estate property in DeKalb County, totaling approximately

21.4 acres. An apartment complex, known as the Hidden Colony Apartments, and

designated Class B by the Board, is situated on the property. In 2015, the Board

valued the subject property at $8,503,560. Aztec appealed the Board’s assessment in

accordance with OCGA § 48-5-311, and, after a hearing before the BOE, a final fair

market combined value of $7,620,948 was established for the property for tax year

2015. Aztec did not appeal this valuation to the superior court.

In May 2016, an appraiser from the DeKalb County Property Appraisal

Department conducted a site visit to the subject property, and recommended an

increase in the valuation based on market conditions. The analysis described that the

2015 valuation was not valued uniformly with other Class B apartments in the same

neighborhood, or in neighborhoods near the subject property. Based on this

information, the Board assessed the subject property at $22,339,565 for tax year

2016, an increase of 166% over the 2015 valuation. Aztec appealed this valuation to

4 the BOE, which decreased the value to $20,339,480. Aztec then appealed this

valuation to the Superior Court of DeKalb County.

In each case, the taxpayer moved for summary judgment, contending that the

two-year freeze provided for in OCGA § 48-5-299 (c) precluded the Board from

increasing the value established by the BOE appeal. In response, the Board argued

that OCGA § 48-5-299 (c) permitted revaluation because the subject properties’

values increased based upon a subsequent significant increase in sales prices of

similar, comparable properties. The trial court granted the taxpayers’ respective

motions for summary judgment, ruling that the Board’s stated basis for increasing the

properties’ valuations—changes in comparable sales—cannot, as a matter of law,

constitute a “material factor” as contemplated by OCGA § 48-5-299 (c) (4).

1. The Board contends that the trial court erred in concluding that under OCGA

§ 48-5-299 (c) (4), a significant increase in sales of comparable properties could not

constitute a “material factor[] that substantially affect[s] the current fair market value”

of the property. OCGA § 48-5-299; see also Ga. Comp. R. & Regs. 560-11-10-.09 (2)

(c) (2). In support of this contention, the Board argues that the plain language of

OCGA § 48-5-299 (c) (4) indicates that evidence of significantly increased sales

prices of like properties can, as a matter of law, constitute a material factor

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