HALL COUNTY BOARD OF TAX ASSESSORS v. WESTREC PROPERTIES, INC. (Five Cases)

303 Ga. 69
CourtSupreme Court of Georgia
DecidedJanuary 29, 2018
DocketS17A1421, S17A1425
StatusPublished
Cited by10 cases

This text of 303 Ga. 69 (HALL COUNTY BOARD OF TAX ASSESSORS v. WESTREC PROPERTIES, INC. (Five Cases)) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HALL COUNTY BOARD OF TAX ASSESSORS v. WESTREC PROPERTIES, INC. (Five Cases), 303 Ga. 69 (Ga. 2018).

Opinion

303 Ga. 69 FINAL COPY

S17A1421. HALL COUNTY BOARD OF TAX ASSESSORS v. WESTREC PROPERTIES, INC. S17A1422. HALL COUNTY BOARD OF TAX ASSESSORS v. PS RECREATIONAL PROPERTIES, I. S17A1423. HALL COUNTY BOARD OF TAX ASSESSORS v. CHATTAHOOCHEE PARKS, INC. S17A1424. HALL COUNTY BOARD OF TAX ASSESSORS v. MARCH FIRST, INC. S17A1425. HALL COUNTY BOARD OF TAX ASSESSORS v. AMP III — LAZY DAYS, LLC.

BOGGS, Justice.

These five essentially identical appeals arise from the assessment of taxes

by the Hall County Board of Tax Assessors (“the Board”).1 The trial court

granted summary judgment in favor of appellee taxpayers based upon the

Board’s failure to schedule a timely settlement conference as required by the

2015 amendment to OCGA § 48-5-311 (g) (2), Ga. L. 2015, p. 1219 et seq. (“the

1 The trial court heard all five cases together and entered the same summary judgment order in each case. All taxpayers are represented by the same counsel, and other than the styles, the specific valuations, and the record references, the briefs are essentially identical and raise the same three issues on appeal. The relevant dates with respect to the tax appeals are the same for all taxpayers. Act”),2 and the Board appeals. Because the plain language of the statute, as

amended by the Act, requires the Board to schedule and notice a settlement

conference with the taxpayer within 45 days of receipt of a taxpayer’s notice of

appeal, and provides that the appeal shall terminate in the event the Board elects

not to do so, we affirm.

The relevant facts are not in dispute. Appellee taxpayers Westrec

Properties, Inc. (Sunrise Cove & Snug Harbor Marinas), PS Recreational

Properties, I (Holiday Marina), Chattahoochee Parks, Inc. (Aqualand Marina),

March First, Inc. (Gainesville Marina), and AMP III — Lazy Days, LLC (Lazy

Days Marina) operate marinas on Lake Lanier in Hall County. The marinas are

located on shoreline property leased from the United States Army Corps of

Engineers. For the 2015 tax year, the Board revised its real property tax

assessments to include the assessed value of docks and other improvements as

part of the leasehold interest instead of personalty, as in previous years. This

increased the assessed value substantially: according to the taxpayers, between

345 and 3,200 percent. On June 1, 2015, the taxpayers appealed to the Board of

Equalization. After hearings on December 10 and December 17 to determine

2 See 2015 Georgia Laws Act 193 (H.B. 202).

2 the fair market value of the taxpayers’ property, the Board of Equalization

upheld the assessments.3

On January 1, 2016, the Act went into effect.4 It extensively amended the

provisions of OCGA § 48-5-311 governing county boards of equalization and

tax appeals, including subsection (g) relating to appeals to superior courts. The

subsection as amended requires the county board of tax assessors to schedule a

settlement conference in the event of the taxpayer’s filing of a notice of appeal

to the superior court. With respect to the latter, subsection (g) (2) provides:

. . . Within 45 days of receipt of a taxpayer’s notice of appeal and before certification of the appeal to the superior court, the county board of tax assessors shall send to the taxpayer notice that a settlement conference, in which the county board of tax assessors and the taxpayer shall confer in good faith, will be held at a specified date and time which shall be no later than 30 days from the notice of the settlement conference, and notice of the amount of the filing fee, if any, required by the clerk of the superior court. The taxpayer may exercise a one-time option to reschedule the settlement conference to a different date and time acceptable to the taxpayer, but in no event later than 30 days from the date of the

3 A hearing was held on December 10, 2015, but due to allegedly inadequate notice a second hearing was held on December 17. After each hearing, the Board of Equalization entered an order upholding the assessment. 4 As noted in Division 2, below, certain provisions of the Act did not go into effect until a later date. However, most provisions, including those governing appeals to the superior courts, became effective on January 1, 2016.

3 notice. If at the end of the 45 day review period the county board of tax assessors elects not to hold a settlement conference, then the appeal shall terminate and the taxpayer’s stated value shall be entered in the records of the board of tax assessors as the fair market value for the year under appeal and the provisions of subsection (c) of Code Section 48-5-299 shall apply to such value. ...

On January 8, 2016, the taxpayers filed with the Board their respective

notices of appeal to the Superior Court of Hall County. The 45-day notice period

provided by OCGA § 48-5-311 (g) (2), as amended by the Act, accordingly

ended on February 22, 2016. On March 8, 2016, the taxpayers mailed to the

Board letters noting the failure to provide timely notice of a settlement

conference and demanding that the Board “(i) enter into the records of the board

of tax assessors the taxpayer’s stated value of [dollar amount], (ii) refund any

overage of taxes paid for the Subject Property for Tax Year 2015, and (iii)

reimburse the [taxpayer] its costs of litigation and reasonable attorney’s fees

accumulated in this matter.” On March 17, 2016, the Board’s counsel

responded, declining to comply with the taxpayers’ March 8 demands.

On June 10, 2016, the Board provided notice to the taxpayers of a

settlement conference scheduled for June 20, 2016. On June 13, 2016, prior to

the settlement conference, the Board certified the appeal to the Superior Court

4 of Hall County. On June 20, 2016, the taxpayers’ attorney, under protest,

attended the settlement conference with the Board. Unable to agree on a fair

market value, the parties proceeded with the superior court litigation.

On July 15, 2016, the taxpayers filed their motions for summary

judgment. After oral argument, the trial court found that the revised version of

OCGA § 48-5-311 (g) (2) applied to the parties, that the Board failed to send

notice of a settlement conference within 45 days and before certifying the

appeal, and that the Board therefore elected not to hold a settlement conference

within the mandatory time provided by statute. It therefore granted summary

judgment in favor of all taxpayers, directed that the Board enter the taxpayers’

stated values and that the valuation carry forward in accordance with OCGA §

48-5-299 (c). The trial court also determined that the taxpayers were entitled to

attorney fees pursuant to OCGA § 48-5-311 (g) (4) (B) (ii), and that the statute

was not unconstitutional on the grounds asserted by the Board. This appeal by

the Board followed.

1. Relying upon Ga. Const. Art. I, Sec. II, Par. III,5 the Board complains

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