In re: Oak Meadows Cmty. Ass'n

CourtCourt of Appeals of North Carolina
DecidedMarch 19, 2024
Docket23-728
StatusPublished

This text of In re: Oak Meadows Cmty. Ass'n (In re: Oak Meadows Cmty. Ass'n) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Oak Meadows Cmty. Ass'n, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-728

Filed 19 March 2024

Property Tax Commission, No. 22 PTC 40

IN THE MATTER OF THE APPEAL OF:

OAK MEADOWS COMMUNITY ASSOCIATION, Appellant

From the decision of the Randolph County Board of Equalization and Review concerning the exemption of certain real property.

Appeal by taxpayer-appellant from final decision entered 28 February 2023 by

the North Carolina Property Tax Commission sitting as the State Board of

Equalization and Review. Heard in the Court of Appeals 23 January 2024.

Robinson, Bradshaw & Hinson, P.A., by Emily J. Schultz, H. Hunter Bruton, Emma W. Perry, Curtis C. Strubinger, and Timothy P. Misner, for taxpayer- appellant.

Poyner Spruill LLP, by Emily M. Meeker and N. Cosmo Zinkow, for appellee Randolph County.

ZACHARY, Judge.

This appeal raises a single issue of law: the definition of the phrase “providing

housing” as used in the property tax exemption provided for “[r]eal and personal

property owned by . . . [a] nonprofit organization providing housing for individuals or

families with low or moderate incomes[.]” N.C. Gen. Stat. § 105-278.6(a)(8) (2023)

(emphasis added). Oak Meadows Community Association (“Oak Meadows”) applied

for this exemption, which the Randolph County Board of Equalization and Review IN RE: OAK MEADOWS CMTY. ASS’N

Opinion of the Court

(“Randolph County”) denied. Oak Meadows now appeals from the final decision of the

North Carolina Property Tax Commission (“the Commission”), which affirmed

Randolph County’s denial of Oak Meadows’s request. After careful review, we affirm.

I. Background

Oak Meadows is a North Carolina nonprofit organization, and its purpose is

“to own and maintain land as a manufactured home community with the goal of a

permanently affordable, safe, and stable environment in which its current and future

members shall live as residents[.]” Oak Meadows owns approximately 3.74 acres of

land (“the Property”) in Asheboro, North Carolina. The Property has the

infrastructure to operate as a manufactured home community (“MHC”)

accommodating 60 manufactured homes.

Oak Meadows is structured as a leased-land housing cooperative, in which its

members are residents on the Property. Oak Meadows’s members own their

manufactured homes individually, and Oak Meadows has no ownership interest in

any of the homes. No individual obtains a financial return on investment through

membership in Oak Meadows.

On 9 February 2022, Oak Meadows requested a property tax exemption

pursuant to § 105-278.6(a)(8) for the Property. On 16 February 2022, Randolph

County denied Oak Meadows’s request, concluding that “housing is not being

provided for individuals or families with low or moderate incomes.” Oak Meadows

timely appealed to the Commission, before which the matter came on for hearing on

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9 November 2022.

On 28 February 2023, the Commission issued its final decision, affirming the

denial of Oak Meadows’s request. The Commission found as fact:

2. There appears to be no dispute that the manufactured homes situated in the MHC on the [Property] are individually owned, and that [Oak Meadows] has no ownership interest in the manufactured homes. Accordingly, we find that [Oak Meadows] owns only the underlying land within the MHC and does not own any of the homes themselves.

3. Although [Oak Meadows] owns the MHC land, we note that land alone is insufficient to house an individual or family. [Oak Meadows] facilitates manufactured home lot rentals for its members, but since individual homeowners must secure their own manufactured housing separately from leasing lots within the MHC, we find that [Oak Meadows] does not “provid[e] housing for individuals or families.”

Based on these findings of fact, the Commission concluded:

2. The plain language of N.C. Gen. Stat. §105-278.6 provides that a property owner must be engaged in “providing housing for individuals or families with low or moderate incomes” in order to receive the benefit offered by the statute. [Oak Meadows] does not provide housing by solely owning the rental lots in a MHC, and the individual homeowners are responsible for securing their own homes to place upon the rental lots. Accordingly, [Oak Meadows] does not qualify for the benefit offered by N.C. Gen. Stat. §105-278.6.

3. Although [Oak Meadows] contends that granting the requested exemption is consistent with the policy of the State in promoting the creation of housing for

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low and moderate income households, we find there to be no ambiguity in the language of the statute that would allow for the requested exemption under the facts of this case, and note further that the Commission has no authority to override the stated intent of the General Assembly.

Consequently, the Commission affirmed Randolph County’s denial of Oak

Meadows’s request. Oak Meadows timely filed notice of appeal.

II. Discussion

Oak Meadows argues that the Commission erred as a matter of law by denying

its request for a property tax exemption because the Commission’s “atextual

interpretation cannot be squared with [N.C. Gen. Stat. § 105-278.6(a)(8)]’s plain

meaning, or [its] statutory structure and purpose.” We disagree.

A. Standard of Review

On appeal from a decision of the Commission, this Court “shall decide all

relevant questions of law, interpret constitutional and statutory provisions, and

determine the meaning and applicability of the terms of any Commission action.”

N.C. Gen. Stat. § 105-345.2(b). This Court

may affirm or reverse the decision of the Commission, declare the decision null and void, or remand the case for further proceedings; or it may reverse or modify the decision if the substantial rights of the appellants have been prejudiced because the Commission’s findings, inferences, conclusions, or decisions are any of the following:

(1) In violation of constitutional provisions.

(2) In excess of statutory authority or jurisdiction of

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the Commission.

(3) Made upon unlawful proceedings.

(4) Affected by other errors of law.

(5) Unsupported by competent, material, and substantial evidence in view of the entire record as submitted.

(6) Arbitrary or capricious.

Id. “In making these determinations, the court shall review the whole record or the

portions of it that are cited by any party, and due account shall be taken of the rule

of prejudicial error.” Id. § 105-345.2(c).

“The taxpayer bears the burden of proving that its property meets the

requirements of an ad valorem taxation exemption.” In re Blue Ridge Hous. of

Bakersville LLC, 226 N.C. App. 42, 49, 738 S.E.2d 802, 807 (2013) (cleaned up), disc.

review improvidently allowed, 367 N.C. 199, 753 S.E.2d 152 (2014). “Issues of

statutory construction are questions of law, reviewed de novo on appeal.” Id. (cleaned

up). When conducting de novo review, the appellate court “considers the matter anew

and freely substitutes its own judgment for that of the Commission.” Id. (citation

omitted).

B. Analysis

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Bluebook (online)
In re: Oak Meadows Cmty. Ass'n, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-oak-meadows-cmty-assn-ncctapp-2024.