Nardi v. Multnomah County Assessor

CourtOregon Tax Court
DecidedMay 28, 2020
DocketTC-MD 190108N
StatusUnpublished

This text of Nardi v. Multnomah County Assessor (Nardi v. Multnomah County Assessor) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nardi v. Multnomah County Assessor, (Or. Super. Ct. 2020).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

NICHOLAS NARDI ) and ELIZABETH NARDI, ) ) Plaintiffs, ) TC-MD 190108N ) v. ) ORDER DENYING PLAINTIFFS’ ) MOTION FOR SUMMARY MULTNOMAH COUNTY ASSESSOR, ) JUDGMENT; GRANTING ) DEFENDANT’S MOTION FOR Defendant. ) SUMMARY JUDGMENT

Plaintiffs filed their Complaint on April 8, 2019, appealing a Multnomah County Board

of Property Tax Appeals (BOPTA) Order concerning the value of property identified as Account

R298115 (the Garfield Property) for the 2018-19 tax year. Plaintiffs challenge the Garfield

Property’s 2018-19 maximum assessed value (MAV), alleging that it should be approximately

$170,000 rather than $509,600. 1 (Compl at 6.) The parties submitted cross-motions for

summary judgment. Oral argument was held on November 5, 2019. Nicholas A. Nardi appeared

on behalf of Plaintiffs, and Carlos A. Rasch, Assistant County Attorney, appeared on behalf of

Defendant. All material facts were stipulated to by the parties.

I. STATEMENT OF FACTS

In 2003, the Garfield Property qualified for a 15-year special assessment as a historic

property under “ORS 358.475 et seq (2003).” (Stip Facts at ¶ 3). “Pursuant to the historic

special assessment, the owners of the Garfield Property received a special tax assessment in

exchange for rehabilitating the Property.” (Id. at ¶ 4.) The prior owners of the Garfield Property

1 Defendant initially determined a MAV of $603,259, but it was reduced by the BOPTA. (See Compl at 2).

1 ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT; GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 190108N and Plaintiffs undertook rehabilitative work that cost in excess of $25,000, including restoring

cement stairs, power-washing and repairing cement exteriors, replacing two cement columns,

rebuilding the cement porch, painting wooden exteriors, and repairing the roof. (Id. at ¶¶ 5-6.)

The special assessment term expired in 2018. (Id. at ¶ 8.) Prior to receiving special assessment,

the Garfield Property’s 2002-03 real market value (RMV) was $353,380; its MAV was

$121,530; and its tax liability was $2,577. (Stip Facts at 2, ¶ 4). For the 2003-04 tax year, the

first year of special assessment, the Garfield Property’s RMV was $403,030; its MAV was

$83,310; and its tax liability was $1,868. (Id. at ¶ 4.) In the years 2003 to 2018, Defendant did

not increase the Garfield Property’s MAV due to improvements to the property. (Id. at ¶ 7.)

When the special assessment expired, Defendant determined the Garfield Property’s 2018-19

RMV was $1,040,000; its MAV was $509,600; and its tax liability was $12,409. (Id. at ¶ 8.)

“The tax savings realized by the owners of the Garfield Property were under $25,000 for the

entire special assessment term.” (Id. at ¶ 5.)

II. ANALYSIS

The issue before the court is whether the Garfield property’s 2018-19 MAV must be

recalculated under Article XI, section 11 of Oregon’s Constitution following expiration of the

historic property special assessment.

In all proceedings before this court, the party seeking affirmative relief shall bear the burden of

proof by a preponderance of the evidence. ORS 305.427.2 A “[p]reponderance of the evidence means

the greater weight of evidence, the more convincing evidence.” Feves v. Dept. of Rev., 4 OTR 302,

312 (1971). The court shall grant summary judgment “if the pleadings, depositions, affidavits,

2 The court’s references to the Oregon Revised Statutes (ORS) are to 2017, except where otherwise noted. 2 ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT; GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 190108N declarations, and admissions on file show that there is no genuine issue as to any material fact and that

the moving party is entitled to prevail as a matter of law.” Tax Court Rule 47 C. “A party opposing

summary judgment cannot rest upon the allegations of [its] pleadings[, but] must ‘disclose the merits of

[its] case or defense.” Eugene Television, Inc. v. Flinn, 43 Or App 837, 841, 604 P2d 437 (1979).

A. Parties Arguments

Plaintiffs argued that the “substantial increase in [MAV] is inconsistent with the

limitations imposed by Article XI * * *.” (Ptfs’ Mot for Summ J at 3.) Plaintiffs identified three

bases in opposition to the 2018-19 MAV adjustment. First, that the MAV calculation in

subsection (c) was only intended to apply where property had not received a MAV in 1997 prior

to special assessment. 3 (Id. at 8.) Second, that expiration of the special assessment under ORS

358.515 does not meet the definition of “disqualified” under section 11(1)(c). 4 (Id. at 15.)

Third, that recalculating the MAV unfairly penalizes Plaintiffs for participating in the historic

property special assessment program. (Ptfs’ Resp at 2; Ptf’s Reply at 2.)

Defendant argued that the plain text of section 11 provides that disqualification from

special assessment is one of the events triggering a recalculation of MAV under subsection (c).

Section 11(1)(c)(E) makes no exception for property that already had a MAV calculated prior to

entering special assessment. Defendant further argued that ORS 356.515 and ORS 356.540 both

state that property is disqualified from special assessment after the period of special assessment

ends and that no different meaning can be inferred under section 11.

3 “The legislature (and Oregon voters) never intended subsection (1)(c) to apply to property which was revalued in 1997 pursuant to subsections (1)(a) and (1)(b), and then later became specially assessed.” (Ptf’s Mot Summ J at 8.) 4 Plaintiffs note that under the version of ORS 358.515 in effect when they entered the program, expiration of the special assessment period was not explicitly included as a disqualifying event. See ORS 358.515 (2003). However, ORS 358.540 (2003) provided that property “at the completion of the 15-year term, is disqualified * * *.” 3 ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT; GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 190108N B. Measure 50, Generally

Article XI, section 11 (section 11), of the Oregon Constitution, also known as Measure

50, was adopted by the voters in 1997. AKS LLC v. Dept. of Rev., __ OTR __ (Apr 18, 2019)

(Slip Op at 16-17). Before Measure 50 was adopted, property taxes were based on the property’s

RMV. Id. at 16. Measure 50 created the concept of MAV and provided that taxpayers shall be

taxed the lesser of RMV or MAV. Id.; see also Or Const, Art XI, § 11(1)(f). MAV cannot

increase more than three percent per year. Or Const, Art XI, § 11(1)(b). However, that three

percent rule is subject to several exceptions, including property disqualified from special

assessment. Or Const Art XI, § 11(1)(c)(E). If an exception applies, the property is “valued at

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Farmers Ins. Co. of Oregon v. Mowry
261 P.3d 1 (Oregon Supreme Court, 2011)
Shilo Inn Portland/205, LLC v. Multnomah County
36 P.3d 954 (Oregon Supreme Court, 2001)
State v. Langley
839 P.2d 692 (Oregon Supreme Court, 1992)
Martinez v. Kulongoski
185 P.3d 498 (Court of Appeals of Oregon, 2008)
State v. Kelly
211 P.3d 932 (Court of Appeals of Oregon, 2009)
Portland General Electric Co. v. Bureau of Labor & Industries
859 P.2d 1143 (Oregon Supreme Court, 1993)
State v. Sagdal
343 P.3d 226 (Oregon Supreme Court, 2015)
Feves v. Department of Revenue
4 Or. Tax 302 (Oregon Tax Court, 1971)
Haynie v. Dept. of Rev.
19 Or. Tax 488 (Oregon Tax Court, 2008)
Ellis v. Lorati
14 Or. Tax 525 (Oregon Tax Court, 1999)
Stonebridge Life Insurance v. Department of Revenue
18 Or. Tax 461 (Oregon Tax Court, 2006)
Living Enrichment Center Prop. v. Dept. of Rev
19 Or. Tax 324 (Oregon Tax Court, 2007)
Dish Network Corp. v. Dep't of Revenue
434 P.3d 379 (Oregon Supreme Court, 2019)
Eugene Television, Inc. v. Flinn
604 P.2d 437 (Court of Appeals of Oregon, 1979)

Cite This Page — Counsel Stack

Bluebook (online)
Nardi v. Multnomah County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nardi-v-multnomah-county-assessor-ortc-2020.