HomeMy WebLinkAbout09-7455IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA.
CIVIL ACTION - LAW
IN RE:
No. 0-9- 7 Y.SS C:v--( 7;,
APPEAL OF RITE AID OF PA, INC.
FROM THE CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005 Real Estate Tax
Assessment Appeal
MUNICIPALITY: HAMPDEN TOWNSHIP
SCHOOL DISTRICT: CUMBERLAND VALLEY
ASSESSMENT FOR THE YEAR 2009
PROPERTY OF RITE AID OF PA, INC.
PETITION FOR REVIEW
OF COMMERCIAL REAL PROPERTY ASSESSMENT
TO THE HONORABLE JUDGES OF SAID COURT:
1. The petitioner is RITE AID OF PA, INC.; duly authorized to transact business in Pennsylvania with a
place of business located at 4957 Carlisle Pike, HAMPDEN TOWNSHIP, CUMBERLAND COUNTY,
Pennsylvania.
2. The respondent is the CUMBERLAND County Board of Assessment Appeals whose address is:
CUMBERLAND County Board of Assessment Appeals, Old Courthouse, One Courthouse Square, Carlisle,
PA 17013.
3. The petitioner is the owner of property located at 4957 Carlisle Pike, HAMPDEN TOWNSHIP,
CUMBERLAND COUNTY, which is identified for local real estate tax purposes as Parcel No. 10-21-0279-
0005 (hereinafter referred to as "Premises).
4. The County of CUMBERLAND, the municipality of HAMPDEN TOWNSHIP, and the
CUMBERLAND VALLEY School District are the taxing bodies interested in the taxable status of the
Premises.
5. Sometime in 2009, the petitioner was informed that the assessment of the premises for local real
estate tax purposes was fixed for the 2010 tax year at $975,710.
6. The petitioner filed notice of its intention to appeal this assessment to the CUMBERLAND County
Board of Assessment Appeals (`Board") and a Hearing was held on October 13, 2009.
7. The petitioner was informed that the Board revised the assessment based on hearing to $767,270 (See
Exhibit "A" annexed hereto.)
8. The assessment for the premises as fixed by the Board is excessive, improper, unjust and contrary to
law for the following reasons:
(a) The assessment is based in whole or in part upon an appraisal that does not represent the actual
value of the premises;
(b) The ratio of assessed value to actual value applied in making the assessment is in excess of the
ratio applied by the taxing authority;
(c) The assessment lacks uniformity;
(d) The assessment is discriminatory;
(e) The assessment is otherwise unjust and inequitable.
WHEREFORE, the petitioner requests that the Court review and reduce the assessment for the
premises fixed for the taxable year 2010 and make such other orders and decrees with respect thereto as shall
be just and proper.
Jf OLD F. JANAT 4 /
A ORNEY FOR PE ?fNER
ORNEY ID. NO. 60898
605 NORTH BROAD STREET
LANSDALE, PENNSYLVANIA 19446
DATED: October 23, 2009 (215) 362-7772
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
IN RE:
APPEAL OF RITE AID OF PA, INC.
FROM THE CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY: HAMPDEN TOWNSHIP
SCHOOL DISTRICT: CUMBERLAND VALLEY
ASSESSMENT FOR THE YEAR 2009
PROPERTY OF RITE AID OF PA, INC.
Real Estate Tax
Assessment Appeal
CERTIFICATION OF VERIFICATION
1. I, Jerrold F. Janata, am an Attorney-at-Law of the Commonwealth of Pennsylvania and have been
retained to represent the petitioner, RITE AID OF PA, INC., in the within cause of action.
2. I have been authorized to file this petition on behalf of the petitioner.
3. This Certification of Verification is not executed by an officer of the petitioner because the
verification could not be obtained within the time prescribed to effect its appeal by statute and rules of the
Court.
4. 1 am familiar with all of the facts contained in this petition.
5. I certify that all of the facts set forth in this Petition are true and correct to the best of my knowledge
and belief. I further certify that if any of the foregoing statements are willfully incorrect, I am subject to
penalties as stated in the Pennsylvania Crimes Code, 18 PA.C.S. 4904, relating to unsworn falsification to
authorities.
F. JANATA
"ATTORNEY ID. NU. 60898
605 NORTH BROAD STREET
LANSDALE, PENNSYLVANIA 19446
DATED: October 23, 2009 (215) 362-7772
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA.
CIVIL ACTION - LAW
IN RE:
APPEAL OF RITE AID OF PA, INC.
FROM THE CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY: HAMPDEN TOWNSHIP
SCHOOL DISTRICT: CUMBERLAND VALLEY
ASSESSMENT FOR THE YEAR 2009
PROPERTY OF RITE AID OF PA, INC.
NOTICE OF APPEARANCE
PLEASE, enter the appearance of
JERROLD F. JANATA
Attorney at Law
Attorney Id. No. 60898
605 North Broad Street
Lansdale, Pennsylvania 19446
(215) 362-7772
No.
Real Estate Tax
Assessment Appeal
as attorney for the petitioner, RITE AID OF PA, INC. , in the above captioned action. Please direct any and
all correspondence and/or communications to said attorney at the address and/or telephone number set forth
above.
Yours, etc.,
Cumberland County Board of Assessment Appeals
Old Courthouse
One Courthouse Square (717) 240-6350
Carlisle, PA 17013 (717) 240-6354 (fax)
Board of Assessment Appeals BONNIE M. MAHONEY
Lloyd W. Bucher Chief Assessor
R. Fred Hefelfinger
Sarah Hughes STEPHEN D. TILEY
Assistant Solicitor
DECISION ORDER
MAILING DATE: October 14, 2009
PARCEL NUMBER: 10-21-0279-005.
RITE AID OF PENNSYLVANIA
JERROLD F JANATA
605 NORTH BROAD STREET
LANSDALE PA 19446
Dear Property Owner:
This letter is to officially notify you of the decision of the Cumberland County Board of Assessment Appeals
regarding the above-referenced parcel.
DATE OF APPEAL HEARING: 10/13/2009
DATE DECISION RENDERED: 10/13/2009
EFFECTIVE FOR TAX YEAR: 2010
DECISION RENDERED: [ J Withdrawn By Applicant
[ ] Abandoned For Failure To Appear
[ ] Denied - No Change
[ ] Approved Review Appraiser's Changes
[X] Revised Assessment Based on Hearing
[) Other:
TOTAL VALUE FAIR MARKET CLEAN AND GREEN CLEAN AND GREEN
STATUS
Old Assessed Value: 975,710 NOT
New Assessed Value: 767,270 APPLICABLE
Any person aggrieved by the order of the Board of Assessment may appeal to the Court of Common
Pleas by filing a petition in the Prothonotary's office on or before November 13, 2009.
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OCT 2 9 2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA.
CIVIL ACTION - LAW
IN RE:
APPEAL OF RITE AID OF PA, INC.
FROM THE CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY: HAMPDEN TOWNSHIP
SCHOOL DISTRICT: CUMBERLAND VALLEY
ASSESSMENT FOR THE YEAR 2009
PROPERTY OF RITE AID OF PA, INC.
ORDER
7 115'1(
No0 9 - I s"S Ccv?l ?Te ?„
No.
Real Estate Tax
Assessment Appeal
AND NOW, this ? day ofQu-, 2009, upon consideration of the foregoing Petition
for Review of Real Estate Assessment, it is hereby ordered pursuant to the Act of June 26, 1931,
P.L. 1379. Section 9, as amended (72 P.S. Section 5350) that with twenty (20) days after the date of
entry by the Court of this Order, the Petitioner shall mail, by certified mail, a copy of the Petition
and Order to the following: The Board of Assessment Appeals; the County Solicitor; the
Municipality in which the tax parcel is located; and the School District in which the tax parcel is
located. Within thirty (30) days after the entry of this Order, the petitioner shall file an affidavit of
service with the Prothonotary.
Any person or governmental agency upon whom a copy of the Petition and this Order is
required to be served as stated above, may file a reply or may intervene in the appeal proceedings as
a matter of right by filing with the Prothonotary, within twenty (20) days after receipt of the copy of
a Petition and Order, either a response to the Petition or a praecipe directing intervention as an
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2099 OCT 30 AN 11: 37
appellant or appellee, as the case may be. If such response or praecipe has not been filed within the
required twenty (20) day period, intervention thereafter shall be governed by Pennsylvania Rules of
Civil Procedure 2326 through 2350 inclusive.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA.
CIVIL ACTION - LAW
IN RE:
APPEAL OF RITE AID OF PA, INC.
FROM THE CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY: HAMPDEN TOWNSHIP
SCHOOL DISTRICT: CUMBERLAND VALLEY
ASSESSMENT FOR THE YEAR 2009
PROPERTY OF RITE AID OF PA, INC.
No. pq - 74 S,S (.:ivi l't
Real Estate Tax
Assessment Appeal
CERTIFICATION OF SERVICE
This is to certify that in this case complete copies of the Petition for Review of Commercial Real
Property Assessment were served upon the following persons at the following addresses by certified mail,
return receipt requested on the day o 2009:
CUMBERLAND County
Board of Assessment Appeals
Old Courthouse, One Courthouse Square
Carlisle, PA 17013
CUMBERLAND County
Office of the Solicitor
Old Courthouse, One Courthouse Square
Carlisle, PA 17013
CUMBERLAND VALLEY School District
Office of the Superintendent
6746 Carlisle Pike
Mechanicsburg PA 17050
HAMPDEN TOWNSHIP
Township Manager
230 S. Sporting Hill Road
Mechanicsburg, PA 17050
3i ?9
DATED: Osjobw-23 2605
LANSDALE, PENNSYLVANIA 19446
(215) 362-7772
605 NORTH BROAD STREET
riGETAF?Y
OF TisP 1
20Qg NOV -6 PM E : t# I
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Stephen D. Tiley, Esquire Supreme Court I.D. No.32318
Attorney for Cumberland County
Board of Assessment Appeals
5 South Hanover Street Tel: 717-243-5838
Carlisle. Pennsylvania 17013 Fax: 717-243-6441
IN RE: APPEAL OF RITE AID : IN THE COURT OF COMMON PLEAS
OF PA, INC. : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
FROM THE
CUMBERLAND COUNTY NO. 2009-7455 CIVIL TERM
BOARD OF ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY:HAMPDEN TOWNSHIP: REAL ESTATE TAX
SCHOOL DISTRICT: CUMBERLAND ASSESSMENT APPEAL
VALLEY.
ASSESSMENT FOR THE YEAR 2010.
PROPERTY OF RITE AID OF PA, INC.
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Respondent, Cumberland County Board of
Assessment Appeals, in the above captioned matter.
Dated: Respectfully submitted,
By
Stephen . Tiley, Esquire
Attorney for Cumberland County Board
of Assessment Appeals
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
Supreme Court I.D.#32318
FILED --- 0,r*FCE
,C)F THE PIRD "i")NN NARY
2009 NOV 23 AM 1 ! : 2 3
V ?II•?4.y lei ;V ;.f?w?ljUN, }
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Stephen D. Tiley, Esquire Supreme Court I.D. No.32318
Attorney for Cumberland County
Board of Assessment Appeals
5 South Hanover Street Tel: 717-243-5838
Carlisle. Pennsylvania 17013 Fax: 717-243-6441
IN RE: APPEAL OF RITE AID : IN THE COURT OF COMMON PLEAS
OF PA, INC. : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
FROM THE
CUMBERLAND COUNTY NO. 2009-7455 CIVIL TERM
BOARD OF ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY:HAMPDEN TOWNSHIP: REAL ESTATE TAX
SCHOOL DISTRICT: CUMBERLAND ASSESSMENT APPEAL
VALLEY.
ASSESSMENT FOR THE YEAR 2010.
PROPERTY OF RITE AID OF PA, INC.
ANSWER
AND NOW, comes Cumberland County Board of Assessment Appeals, by Stephen D.
Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters, and files this Answer to
the Petition for Review of Commercial Real Property Assessment, of which the following is a
statement:
Admitted. The name and address carried by the Assessment Office for the owner
is Rite Aid of Pennsylvania, Incorporated, P.O. Box 3165, Harrisburg, PA 17105.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted. By way of further Answer, the assessment of $975,710 implies a fair
market value of $1,233,515. This appeal is of the assessment for the year 2010, notwithstanding
2009 being mentioned in Petitioner's caption.
6. Admitted.
7. Admitted. By way of further Answer, the Board determined the fair market value
of the property to be $970,000, which resulted in an assessment of $767,270. The appeal to
Court being de novo, the assessment appealed is the original assessment of $975,710.
8. Denied. The averments of this paragraph and each of its sub-lettered paragraphs,
set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is
demanded.
WHEREFORE, Respondent, Cumberland County Board of Assessment Appeals, prays
Your Honorable Court for an Order denying the Appeal or setting the fair market of the property
at such amount as the Court may deem just and proper.
Dated: ;WO7 Respectfully submitted,
By
Stephen D. Tiley, Esquire
Assistant Cumb. Cty. Solicitor For Tax Matters
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
Supreme Court I.D.#32318
.,
VERIFICATION
I verify that the statements made in the foregoing Answer are true and correct,
partially upon personal knowledge and partially upon my belief; to the extent language
in the Answer is that of my attorneys, I have relied upon my attorneys in making this
Verification. I understand that false statements herein are made and subject to the
penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
1197
Dated: /// Bonnie M. Mahoney, Chief Asses or
Stephen D. Tiley, Esquire Supreme Court I.D. No.32318
Attorney for Cumberland County
Board of Assessment Appeals
5 South Hanover Street Tel: 717-243-5838
Carlisle. Pennsylvania 17013 Fax: 717-243-6441
IN RE: APPEAL OF RITE AID : IN THE COURT OF COMMON PLEAS
OF PA, INC. : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
FROM THE
CUMBERLAND COUNTY NO. 2009-7455 CIVIL TERM
BOARD OF ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY:HAMPDEN TOWNSHIP: REAL ESTATE TAX
SCHOOL DISTRICT: CUMBERLAND ASSESSMENT APPEAL
VALLEY.
ASSESSMENT FOR THE YEAR 2010.
PROPERTY OF RITE AID OF PA, INC.
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the foregoing Answer by
placing a certified true and correct copy of the same in the United States mail, postage
pre-paid, addressed to:
Jerrold F. Janata, Esquire Keith O. Brenneman, Esquire
Attorney for Petitioner Solicitor for Hampden Township
605 North Broad Street Snelbaker & Brenneman
Lansdale, PA 19446 44 West Main Street
Mechanicsburg, PA 17055
Jerry R. Duffie, Esquire
Solicitor for Cumberland Valley School District
Johnson, Duffie
301 Market Street
Lemoyne, PA 17043
Date: ?2?.f <,27
v.
Stephen D. Tiley, Esquire
Assistant Cumb. Co. Solicitor
5 S. Hanover Street
Carlisle, PA 17013
(717) 243-5838
Attorney I.D.#32318
FILED -t. t;FIGE
OF TH - PPOTHO 'OTARY
2009 NOV 23 AM 11: 2 3
CUM .j IN i Y
i E-i•,l \ S'YLVAW'A
Stephen D. Tiley, Esquire Supreme Court I.D. No.32318
Attorney for Cumberland County
Board of Assessment Appeals
5 South Hanover Street Tel: 717-243-5838
Carlisle Pennsylvania 17013 Fax: 717-243-6441
IN RE: APPEAL OF RITE AID : IN THE COURT OF COMMON PLEAS
OF PA, INC. : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
FROM THE
CUMBERLAND COUNTY
BOARD OF ASSESSMENT APPEALS
TAX PARCEL NO.: 10-21-0279-0005
MUNICIPALITY:HAMPDEN TOWNSHIP:
SCHOOL DISTRICT: CUMBERLAND
VALLEY.
ASSESSMENT FOR THE YEAR 2010.
PROPERTY OF RITE AID OF PA, INC.
NO. 2009-7455 CIVIL TERM
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STIPULATION AND JOINT MOTION FOR AGREED ORDER
AND NOW, this day of D 2010, it is hereby Agreed and
Stipulated by and between the Petitioner, Rite Aid of PA, Inc., by its attorney, Jerrold F.
Janata, Esquire; and Respondent, Cumberland County Board of Assessment Appeals, by
Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters; and
Interested Party, Hampden Township, by Keith O Brenneman, Esquire; and
Interested Party, Cumberland Valley School District by Jerry R. Duffie, Esquire; and is as
follows:
Petitioner filed a "Petition for Review of Commercial Real Property
Assessment" on October 28, 2009. By Order of Court dated October 29, 2009, the Court
provided for service of the Petition, for intervention, and for the parties to request a
Hearing when the case was at issue. The parties have now settled this case.
2. This assessment appeal relates to market value as of August 31, 2009, the
date the appeal was originally filed before the Board of Assessment Appeals, and year
2010 taxes. Cumberland County is now in the process of implementing a Countywide
reassessment. The valuation date for the year 2010 Countywide reassessment is January
1, 2010. The parties stipulate that this appeal shall be effective for the year 2010
Countywide reassessment valuation.
The property which is the subject of this appeal consists of former beer
distributorship property, situate next to a Rite Aid Realty outlet, and known as 4957
Carlisle Park, Mechanicsburg (Hampden Township) Cumberland County, Pennsylvania.
The property is further identified as Cumberland County Tax Parcel No. 10-21-0279-005.
4. The parties stipulate that the total fair market value of the property as of
the date the original appeal was filed before the Board of Assessment Appeals, August
31, 2009, and as of January 1, 2010, is $850,000.
5. (a) As a result of the year 2004 Cumberland Countywide
reassessment, the predetermined ratio for the tax year 2010 is 100% of year 2004 market
value. The common level ratio published in June of 2009, applicable to the year 2010
assessment, is 79.1%. Since the common level ratio varies by more than 15% from the
predetermined ratio, the common level ratio is used to arrive at the assessment of the
property for tax year 2010. The parties stipulate that the assessment of the property for
tax year 2010 shall be $672,400, rounded.
(b) The Fourth to Eighth Class County Assessment Law makes subsequent
years assessments automatically at issue so long as an appeal remains before the Court.
The parties stipulate that the year 2010 Countywide reassessment value is at issue in the
subject appeal. If there were no Countywide reassessment, the assessment for the 2011
tax year would automatically be at issue on September 1, 2010, and the parties stipulate
that it is at issue now. The predetermined ratio for the year 2010 Countywide
reassessment value is 100% of year 2010 value. There is no common level ratio
applicable to the year 2010 Countywide reassessment value. The parties stipulate that for
the year 2010 Countywide reassessment value, first applicable for taxes beginning in year
2011, the fair market value of the property is $850,000, and the assessment shall, be
$850,000. In the event that the year 2010 Countywide reassessment is, for any reason,
not implemented, then the assessment for taxes beginning in year 2011 and thereafter
shall be calculated by application of the current 80.1% common level ratio, and shall be
$680,900, rounded, and that assessment shall continue for future years until changed as
provided by law.
6. The Cumberland County Assessment Office shall allocate the total
assessment between land and improvements as provided by law and the procedures of the
Cumberland County Assessment Office.
7. The assessment applicable to the 2010 tax year, to wit: $672,400, shall be
implemented beginning with year 2010 County and Municipal taxes, and ending with
2010/11 school real estate taxes. The year 2010 Countywide reassessment value of
$850,000 (or the $680,900 assessment if the Countywide reassessment has not been
implemented), and the assessment in that amount, shall be implemented beginning with
year 2011 County and municipal taxes, and beginning with 2011/12 school real estate
taxes. The year 2010 Countywide reassessment value of $850,000 (or the $680,900
assessment if the Countywide assessment has not been implemented) shall be effective
for tax years beginning on and after January 1, 2011, and shall continue thereafter unless
and until changed as otherwise provided by law. In the event of new construction, or
demolition, effecting an assessment after the date hereof, but on or before December 31,
2010, this Stipulation shall establish the value of the property before such new
construction or demolition, and only the value of the new construction or demolition shall
be added to, or deducted from, the assessment.
8. The Cumberland County Assessment Office shall promptly notify the
appropriate taxing bodies of the change in assessment, and instruct the taxing bodies to
make appropriate refunds.
9. Each party to this appeal shall bear its own costs.
10. The Court is requested to enter the proposed Order attached hereto.
11. The undersigned Attorneys each hereby warrant to the other, and to the
parties, and to the Court, that he/she has reviewed this Settlement Stipulation with his/her
client or clients and that he/she has specifically been authorized to enter into this
Settlement Stipulation by his/her client or clients.
Respectfully Submitted,
RITE AID OF PA, INC.
By
Je F. Janata, squir
At rney for Petitioner, Rite Aid of PA, Inc.
605 North Broad Street
Lansdale, PA 19446
Tel. No. (215)-362-7772
Sp. Ct. ID# 60898
CUMBERLAND COUNTY
BOARD OF ASS SSMENT APPEALS
BY
Stephen D. iley, Esquire
Assistant Cumb. Cty. Solicitor for Tax Matters
Attorney for Cumberland County Board of
Assessment Appeals
Frey and Tiley
5 South Hanover Street
Carlisle, PA 17013
Tel No. (717) 243-5838
Supreme Court ID# 32318
TOWNSHIP
BY
Keith O. Brenn n, Esquire
Attorney for ere Party
Hamp nship
Sne ier& Brenne man
est Main Street
Mechanicsburg, PA 17055
HAMPDEN TOWNSHIP
Keith O. Brenneman, Esquire
Attorney for Interested Party
Hampden Township
Snelbaker & Brenneman
44 West Main Street
Mechanicsburg, PA 17055
CUMBERLAND VALLEY SCHOOL DISTRICT
By:
Je R. uffie, uire
A for ey for Interested Party
Cumberland Valley School District
Johnson Duffie Stewart & Weidner
301 Market Street
Lemoyne, PA 17043