In re: Trade Land Co.

CourtCourt of Appeals of North Carolina
DecidedJune 4, 2025
Docket24-884
StatusPublished

This text of In re: Trade Land Co. (In re: Trade Land Co.) 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: Trade Land Co., (N.C. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA 24-884

Filed 4 June 2025

Property Tax Commission, No. 22 PTC 0029

IN THE MATTER OF THE APPEAL OF:

TRADE LAND COMPANY, LLC, Appellant,

FROM THE DECISION OF THE PITT COUNTY BOARD OF EQUALIZATION AND REVIEW.

Appeal by appellant from decision of North Carolina Property Tax Commission

entered 22 March 2024. Heard in the Court of Appeals 9 April 2025.

Brooks, Pierce, McLendon, Humphrey & Leonard, L.L.P., by Daniel L. Colston, S. Leigh Rodenbough IV, and Ashley Hodges Morgan, for appellant.

Pitt County Legal Department, by R. Matthew Gibson, for appellee.

ARROWOOD, Judge.

Trade Land Company, LLC (“appellant”) appeals from the decision of the

North Carolina Property Tax Commission (“the Commission”) affirming the decision

of the Pitt County Board of Equalization and Review (“the Board”) to revoke the

Present-Use Value (“PUV”) status of appellant’s property subject to the decision. For

the following reasons, we affirm the decision of the Commission.

I. Factual Background

This case concerns the County assessor’s alleged failure to provide proper

notice to a corporate landowner before revoking its tax-deferred status as to certain IN RE: TRADE LAND CO., LLC

Opinion of the Court

properties it owns. The following facts are established by the Record and Transcript

of the hearing before the Commission. The facts for the most part are not in dispute.

Brothers Joshua and Will Clark, along with their father Edwin, are members

and managers of appellant, a limited liability company, which owns 47 tax parcels in

Pitt County, North Carolina. For four years, between 2018 and 2021, appellant

participated in the PUV tax-deferral program for 11 of these parcels. The PUV

program allows for the appraisal of property that is used primarily for agriculture,

horticulture, or forestry at that property’s present use value, and for the deferral of

excess taxes that would be otherwise due under the property’s standard valuation.

N.C.G.S. § 105-277.4, 277.3 (2020).

If a business entity is seeking a PUV deferment, its “principal business” must

be one of the above qualifying uses. Id. § 277.2(4)(b)(1). Appellant’s 11 parcels had

qualifying uses; however, as its counsel conceded at the hearing before the

Commission, the appellant’s overall principal business did not. Therefore it is

undisputed under the Record before us that these properties did not qualify for PUV

treatment. Despite this fact, the Pitt County tax assessor at the time of appellant’s

first application to the PUV program advised one of appellant’s managers that it did

qualify for the program, and, following a 2021 audit, appellant was allowed continued

participation on 25 January 2022.

That changed in December 2022. In August 2022, Russell Hill (“Hill”) was

appointed as tax assessor for Pitt County. Thereafter, when appellant sought to sell

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a portion of one its tax-deferred parcels, Hill began to investigate appellant’s PUV

qualification. As a part of his investigation, Hill discovered that appellant was

primarily a real estate business. On 5 December 2022, Hill called Joshua Clark to

inform him that he had determined that appellant’s properties did not qualify for

PUV treatment. That same day, Cynthia Moore, the Pitt County Special Property

Analyst, informed appellant by letter that it did not qualify, that its 11 parcels that

had previously been granted PUV status were being removed from the PUV program,

and that the deferred taxes were now due. Hill emailed Will Clark on 8 December,

explaining that if he would like to appeal the revocation decision, he could either have

it heard at the final meeting of the Board on 12 December, or when the Board began

meeting again in the spring of 2023.

Will Clark elected to attend the 12 December hearing and offered evidence and

presented arguments in support of the LLC’s appeal. The Board affirmed Hill’s

decision to disqualify appellant from the PUV program. The LLC appealed to the

North Carolina Property Tax Commission on 11 January 2023 and the appeal was

heard on 10 January 2024.

At the hearing, appellant argued that it had not been provided proper notice

under N.C.G.S. § 105-296(i), which requires notice prior to the Board’s first meeting

of the year when a property receives a new appraisal or assessment. The Commission

affirmed the decision of the Board. It concluded that N.C.G.S. § 105-394 was

dispositive in the matter, which defines a failure to give notice as an immaterial

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irregularity for purposes of tax assessment and therefore the lack of proper notice

would not affect the decision of the Board. The Commission further concluded that

appellant had actual notice and the opportunity to be heard before the Board.

Appellant filed a notice of appeal to this Court on 18 April 2024.

II. Discussion

Appellant raises two issues on appeal: whether the Commission erred as a

matter of law by relying on N.C.G.S. § 105-394(9), which appellant claims was ruled

unconstitutional by the North Carolina Supreme Court; and whether the Commission

erred as a matter of law in failing to apply the notice requirements of N.C.G.S. § 105-

296(i). We address these arguments as follows: first, we determine whether the

statutory notice requirements were met; second, even assuming these requirements

were not, we answer whether the Commission reliance on N.C.G.S. § 105-394(9) was

in error; and finally, we address whether the notice and opportunity to be heard that

appellant received was in keeping with constitutional strictures.

A. Standard of Review

The scope of our review of a decision of the Property Tax Commission is as

follows:

So far as necessary to the decision and where presented, the 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. The 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

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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 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.

N.C.G.S. § 105-345.2(b) (2023). We review questions of law de novo, where we freely

substitute our own judgment, while issues of sufficiency of evidence are reviewed in

light of the whole record. In re Appeal of Greens of Pine Glen Ltd., 356 N.C. 642, 647

(2003). “Issues of statutory construction are questions of law, reviewed de novo on

appeal.” McKoy v. McKoy, 202 N.C. App. 509, 511 (2010) (citation omitted).

B. Notice Under the Machinery Act

This first inquiry seems simple on its face: whether appellant was provided

with the proper notice required under Subchapter II of the N.C.G.S., also known as

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