Downingtown Area School District v. Chester County Board of Assessment Appeals

819 A.2d 615, 2003 Pa. Commw. LEXIS 165
CourtCommonwealth Court of Pennsylvania
DecidedMarch 20, 2003
StatusPublished
Cited by8 cases

This text of 819 A.2d 615 (Downingtown Area School District v. Chester County Board of Assessment Appeals) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Downingtown Area School District v. Chester County Board of Assessment Appeals, 819 A.2d 615, 2003 Pa. Commw. LEXIS 165 (Pa. Ct. App. 2003).

Opinions

OPINION BY

JUDGE McGINLEY.

Lionville Station S.C. Associates (Lion-ville) appeals from an order of the Court of Common of Chester County (trial court) that assessed the value of Tax Parcel No. 33-01-0032.0000 (Property) for the 2000 tax year at $8,500,000.00.

On March 17, 1999, the Shoppes at Lion-ville Station, LLP, a Pennsylvania Limited Liability Partnership, sold the Property, an 83,488 square-foot neighborhood shopping center, to Lionville for a purchase price of $10,422,978.23. On January 20, 2000, the Chester County Board of Assessment Appeals (Board) assessed the Property at $6,500,000.00 for the 2000 tax year. [617]*617The Downingtown Area School District (District) appealed and a de novo hearing was held. Before the trial court the parties stipulated to the following: 1) that the fair market value of the Property for the 2000 tax year was $8,500,000.00; 2) that the State Tax Equalization Board (STEB) ratio equaled 85.2% of market value for the 2000 tax year; and 3) that the predetermined ratio used to assess taxpayers in Chester County was 100% of fair market value for the 2000 tax year.

Lionville presented the testimony of Robert R. McRae (McRae), Chief Assessor, Richard Anthony Fazio (Fazio), Chief Financial Officer for the School District, David Shooster (Shooster) owner of the Property, and Scott Eiffes (Eiffes), a commercial real estate appraiser.

McRae testified that the Property consisted of 83,488 square feet and was assessed at $6,500,000.00 which amounted to $77.86 per square foot. Notes of Testimony, June 5, 2001, (N.T. 6/5/01) at 14; Reproduced Record (R.R.) at 23a. McRae stated that Chester County has a predetermined ratio of a 100% of market value and that under the “predetermined ratio scenario” the Property should be assessed at $8,500,000.00. N.T. 6/5/01 at 24; R.R. at 33a.

Fazio testified that the School District appealed the assessment after he compared the transfer price of the Property to its assessed value. N.T. 6/5/01 at 27; R.R. at 36a. Fazio also stated that the School District plans to appeal the assessment of other commercial properties. N.T. 6/5/01 at 27; R.R. at 36a.

Shooster testified he believed the original assessment of the Property at $5,833,040.00 was accurate but that he agreed to the Board’s increase to $6,500,000.00 “just to resolve a dispute, so we would not go through what we’re going through here today.” N.T. 6/5/01 at 39; R.R. at 48a. Shooster acknowledged that he paid $10,422,978.23 for the property and that “I think it is worth that much money.” N.T. 6/5/01 at 42; R.R. at 51a.

Eiffes testified that he applied the ratio of assessed value to market value to seven commercial properties (shopping centers) similar to the Property and that the assessed value of these commercial properties was lower than the Property. Notes of Testimony, June 6, 2001, (N.T. 6/6/01) at 14, 31, and 37; R.R. at 63a, 80a, and 86a. However, Eiffes testified on cross that he did not conduct a “complete appraisal” on these properties but “completed an exteri- or inspection similar to a drive-by appraisal.” N.T. 6/6/01 at 43; R.R. at 92a. Finally, Eiffes stated that shopping center owners paid less taxes proportionately than single-family property owners and that “[i]t appears that that would be an inequity in the system.” N.T. 6/6/01 at 47; R.R. at 96a.

The trial court concluded that the proper assessment of the Property for the 2000 tax year was $8,500,000.00:

Lionville argues that in this case setting the assessment at the fair market value, while consistent with the County’s 100% ratio, results in an assessment which is unconstitutional for lack of uniformity.
Lionville’s evidence goes entirely to the issue of whether its property, a shopping center, is uniformly assessed as compared to other shopping centers. In our view, that question is irrelevant as shopping centers do not constitute a class for purposes of considering the uniformity of tax assessments.... Indeed, the very argument advanced" by Lionville would result in an improper assessment. Taxing commercial, industrial, and residential real estate differently has been held to violate the Uniformity Clause. Fidel[618]*618ity Bank, N.A. v. Com. By and Through Dept. of Revenue, 165 Pa.Cmwlth. 524, 645 A.2d 452 (1994). Therefore, we found Lionville’s position to be without merit and we set the assessment in accordance with the stipulated fair market value.
For the foregoing reasons and those reasons set forth in the footnote[1] to our decision, we rendered the decision from which this appeal has been taken.

Opinion of the Trial Court, March 26, 2002, at 2-4.

On appeal2, Lionville again contends that the trial court’s application of the predetermined ratio of 100% to the Property violated the principles of uniformity and equal protection.3 Succinctly, Lion-ville asserts that its shopping center was assessed higher than other shopping centers in Chester County and therefore the assessment violated the uniformity clause.

Article VIII, Section 1 of the Pennsylvania Constitution provides that “[a]ll taxes shall be uniform, upon the same class of subjects, within the territorial limits of the authority levying the tax, and shall be levied and collected under general laws.” “In matters of taxation, allegations of violations of the equal protection clause of the United States Constitution and the uniformity clause of the Pennsylvania Constitution are analyzed in the same manner, requiring equality of burden upon classes or things subject to the tax in question.” Equitable Life Assurance Society of the United States v. Murphy, 153 Pa.Cmwlth. 338, 621 A.2d 1078, 1086 n. 12 (1993), citing Aldine Apartments, Inc. v. Commonwealth, 493 Pa. 480, 426 A.2d 1118 (1981). Further, “a [619]*619taxpayer alleging that the administration of a tax violates its rights to be taxed uniformly with others of its class must demonstrate deliberate, purposeful discrimination in the application of the tax before constitutional safeguards are violated.” In re Appeal of Armco, Inc., 100 Pa.Cmwlth. 452, 515 A.2d 326, 329 (1986), citing Commonwealth of Pennsylvania v. Westinghouse Elec. Corp., 478 Pa. 164, 386 A.2d 491 (1978).

Section 1.1 of the “Assessments Law” (Law)4, 72 P.S. § 5342.1 defines the term “common level ratio” as “[t]he ratio of assessed value to current market value used generally in the county as last determined by the State Tax Equalization Board pursuant to the act of June 27, 1947 (P.L. 1046, No. 447), referred to as the State Equalization Board Law.”5 (footnotes omitted).

Section 1.1 of the Law, 72 P.S.

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819 A.2d 615, 2003 Pa. Commw. LEXIS 165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/downingtown-area-school-district-v-chester-county-board-of-assessment-pacommwct-2003.