J.B. Blanda and S.R. Blanda v. Somerset County Board of Assessment Appeals v. Somerset County, Jefferson Twp., and Somerset Area SD

131 A.3d 560, 2016 Pa. Commw. LEXIS 24, 2016 WL 56250
CourtCommonwealth Court of Pennsylvania
DecidedJanuary 6, 2016
Docket1934 C.D. 2014
StatusPublished
Cited by4 cases

This text of 131 A.3d 560 (J.B. Blanda and S.R. Blanda v. Somerset County Board of Assessment Appeals v. Somerset County, Jefferson Twp., and Somerset Area SD) 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
J.B. Blanda and S.R. Blanda v. Somerset County Board of Assessment Appeals v. Somerset County, Jefferson Twp., and Somerset Area SD, 131 A.3d 560, 2016 Pa. Commw. LEXIS 24, 2016 WL 56250 (Pa. Ct. App. 2016).

Opinions

OPINION BY

Senior Judge ROCHELLE S. FRIEDMAN.

James B. Blanda (Blanda) appeals from the September 22, 2014, order of the Court of Common Pleas of Somerset County (trial court) denying Blanda and Suzanne R. Blanda’s (collectively, the Blandas) assessment appeal and affirming the Somerset County Board of Assessment Appeals’ (BAA) decision to correct the Blandas’ property assessment to $85,910. We affirm in part, reverse in part, and remand to the trial court to adjust the assessment accordingly.

The Blandas own 7.49 acres of land (Property) designated as parcel number 001-20-0-003850 in Jefferson Township, Somerset County. The Property is improved with a house in which the Blandas reside and a lodge that is rented out seasonally. In 2008, the Property was assessed at $64,080. In 2013, the Somerset County Assessment Office (Assessment Office) did not perform a county-wide tax assessment but increased the Blandas’ property assessment to $86,440 on June 10, 2013. The lodge was the only part of the Property that affected the increase. The Blandas requested a hearing on the new assessment. After the hearing, the BAA reduced the new assessment to $85,910.1 The Blandas appealed to the trial court.

On September 22, 2014, the trial court held a hearing at which the Blandas claimed that they were “selectively targeted” for reassessment. Blanda testified that he believed his Property was being reassessed on the basis of a zoning change and that none of his similarly situated neighbors were reassessed.

Mary Ann McKenzie, the Assessment Office’s Assistant Chief Assessor, testified that the Assessment Office routinely checks real estate listings and rental listings on the internet to make sure descriptions of real estate located in the county match the assessed descriptions. McKenzie stated that her employees discovered a discrepancy in the Blandas’ property assessment while searching the internet. Specifically, a rental advertisement listed the lodge’s living space at 4,400 square feet, whereas the 2008 assessment descrip[562]*562tion listed its living space at 2,206 square feet.

After the discovery, the Assessment Office sent two field workers to measure the Blandas’ lodge. The field workers determined that: the lodge was not one story, as described in the,2008 assessment, but was two-and-one-half stories; the garage had been measured incorrectly;2 the number of bathrooms was incorrect; and the grading of D-plus was incorrect.3 The field workers gave. McKenzie measurements of the lodge, from which McKenzie made a sketch of the lodge, entered the drawing into. the. computer, and determined the square footage and assessment figures. From this process, McKenzie determined that the lodge was 4,274 square feet. ■. McKenzie further .testified that she only. included the lodge’s interior ■ space and did not include the outside deck or the garage in her calculations.

Candace Jane Rizzo, the Assessment Office’s Chief Assessor, similarly testified that she instructs her .staff to look at newspapers, the internet, and real estate guides to check for discrepancies in assessment information.. If a discrepancy is found, a field worker is sent to the property and corrections are made to the assessment. Rizzo stated that the correct assessment for the Property is $85,910. She further stated that the Assessment Office can correct an assessment if it contains a mistake.

Blanda testified that the last improvements to the Property were done between 1995 and 2000, during a remodeling and rebuilding .project, The Property was reassessed in 20P8, and since-then no improvements have been made to the Property. In 2013, a field worker from the Assessment Office came to the Property with a rental advertisement in hand. The rental advertisement listed the Property at 4,400 square feet. The 2008 assessment card listed the Property at 2,206 square feet. Blanda testified that the discrepancy was advertising hyperbole,, explaining that “when I said 4W400 square feet, I included all of the cement pads where people could go outside. I included the deck spaces. I included all of the storage spaces. I included the hot tub area. I included the fire pit area. All of the places where people could congregate and enjoy the [Property.” (N.T„ 9/22/14, at 25-26.) Blanda stated that the lodge does not have 4,400 square feet of living space and that no improvements have been made to the Property since the last assessment in 2008.

The trial court stated that it was “satisfied based on the testimony of the assessment staff that they do in fact change assessments based on external factors, whether it’s an Internet base or whether [they] happen[] to drive by and recognize that there’s a garage that wasn’t there last year when they dr[o]ve by. Whatever it might be that brings things to their attention, I think that can form a basis for them to go and reassess.” (Id. at 89-90.) The trial court “found that the lodge was incorrectly measured in 2008 at 2,206 square feet, while in reality it was and has been 4,274 square feet.” (Trial Ct. Op. at 4.) On September 22, 2014, the trial court denied the Blandas’ assessment appeal, affirming the corrected assessment. Blanda now appeals to this court.4

[563]*563Initially, Blanda contends that the Assessment Office did not have cause to reassess the Property in 2013. Specifically, Blanda asserts that the reassessment amounted to a spot reassessment, which is defined in section 8802 of the Consolidated County Assessment Law '(Assessment Law) as “[t]he reassessment of a property or properties ... that is hot conducted as part of a countywide revision of assessment and which creates, sustains or increases disproportionality among properties’ assessed values.” 53 Pa.C.S. § 8802. Section 8843 of the Assessment Law provides that “[t]he [cjounty assessment office is prohibited from engaging in the practice of spot reassessment.” 53 Pa.C.S. § 8843.

In In re Young, 911 A.2d 605, 608-09 (Pa.Cmwlth.2006), this court stated five circumstances where a county may reassess property:

It is generally acknowledged that, once a value has been established for a taxable property, that value cannot be changed absent one of the following circumstances: (1) undertaking of a countywide reassessment; (2) appeal of property assessment by either the landowner pursuant to section [8844] of the Assessment Law ... or by the taxing authority under section- [8855] of the Assessment Law ...; (3) need for a downward adjustment is necessary under section [8815] of the Assessment Law ...; (4) need to correct a mathematical- or clerical error [pursuant to section 8816 of the Assessment Law] .,,; or (5) presence of one of the three conditions outlined in section- [8817] of the- Assessment Law.... [5] When none of these circumstances exists, a taxing authority’s reassessment of property constitutes an impermissible spot reassessment.[6]

Here, the Assessment Office corrected the Blandas’ assessment on the basis of a mathematical or clerical error. Section 8816 of the Assessment Law provides:

Clerical and mathematical errors
(a) Correction.

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131 A.3d 560, 2016 Pa. Commw. LEXIS 24, 2016 WL 56250, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jb-blanda-and-sr-blanda-v-somerset-county-board-of-assessment-appeals-pacommwct-2016.