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Home My WebLink About04-4075FROELICH & COMPANY, INC., APPELLANT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, APPELLEE CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHP and SOUTH MIDDLETON SCHOOL DISTRICT, INTERESTED PARTIES. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ ~-q07~ o CIVIL DIVISION PETITION FOR APPEAL AND NOW, this 16th day of August 2004, come FROELICH & COMPANY, INC. ("Appellant"), by and through its attorneys, Irwin & McKnight, and files the within Petition for Appeal, and in support thereof states as follows: Froelich & Company, Inc. is the record owner of a golf course known as Mayapple Golf Links situate at One Mayapple Drive, Carlisle, South Middleton Township, Cumberland County, Pennsylvania (the "Property") and identified as Parcel # 40-09-0533-008 in the Cumberland County assessment records. Cumberland County, South Middleton Township and South Middleton School District are the taxing bodies interested in the taxable status of the Property. The Board of Assessment Appeals of Cumberland County, Pennsylvania (the "Board") is a Board created under the Act of June 21, 1939, P.L. 626, 72 P.S. §5342 etseq., authorized to assess and value real property for the purpose of taxation in counties of the Fourth Class and to hear appeals from said assessments by aggrieved parties. Pertaining to the year 2004, the Cumberland County Assessment Office assessed the Property in the amount of Two Million Three Hundred Thirty Four Thousand Three Hundred Sixty and no/100 ($3,334.360.00) Dollars. As of September 1, 2003, the Property was described for the 2004 tax year on the official records of Cumberland County as follows: Description Land Improvements Assessment $942,000 $697,290 Total $1,639,290 On April 12, 2004, Appellant duly appealed the 2004 assessment to the Board for regress and reduction of said assessment. A copy of said appeal Application is attached hereto and marked as Exhibit "A". 2 After a hearing, the Board refused to change the assessment on the Property for the year 2004 by issuing an Decision Order ("Decision") dated July 15, 2004. A copy of the Decision is attached hereto and marked as Exhibit "B". This Petition is herewith timely presented within thirty (30) days from the mailing date of the Decision since the thirtieth (30) day was a Sunday making the final day of the appeal period Monday, August 16, 2004. Appellant is aggrieved by the Board's adjudication. Specifically, Appellant avers, on information and belief, that the assessment remains unfair, unreasonable and excessive. Appellant further avers as follows: A. The assessment is not equal or uniform with other properties similarly located in Cumberland County. B. There is a complete lack of uniformity in the assessment of real estate within Cumberland County which makes the Property assessment unjust, unreasonable and discriminatory. uses. D. The assessment contains a golf course which has limited transferability into other Other such reasons as will be developed at the time of hearing. 3 WHEREFORE, the Appellant, being aggrieved by the assessment of the Board, files this Petition for Appeal and requests that this Honorable Court herein determine its appeal and decrease the assessment of the Property to such mount as may be fight and proper. By: Respectfully submitted, IRWIN & MCKN1GHT 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Attorney for Appellant Date: August 16, 2004 4 EXHIBIT "A" ., ,,,, ,, ~ .... ! ,l ~.-) ',., '..~ t.,; ~"~ ~ , ASSESSM. I~NT APPEAL - COMMERCL'~,L / iHiT.)UL} Ji ~-~IAL U d si, i~e i~mv~sions (,i law a~r~y person' aggriev,}d by any assessment desiring Io appeal shall lil¢ a statement, in wl'~ling with the Board of Ass~ssmcnt Appeals oh or before ........... Such statement shall designate the assessment appealed fram and the address ~o which Cie Board shatl mai~ re,hca (~ whe~a and where to appear for a hearing. No appeal shall De heard by the board unless appellant shall first have filed the appeal and required documents on or before ..... , as set forlh by law. (') includes taxing districts Record C)wner(s) Na[ne FROELICH & CO,, INC. Address; I ~Y~PLE DRI~ C~ISl,[, PA t7013 o~t( Locahun of Property Subject o[ Appeal: 1 ~Y~PLg DRI~, C~ISLE, PA_t70l]. Scab ~DL~O~ Number Street Emro/Township Assessors l~x Map Identification #: ~O-09-0533-OO8 Assessment Appealed _~ ~_ Opinion of MarNet Value of this Property ~ Date Purchased ~¢_~ember 1994__ Purchase Price $2,250,O00.O0 _ Amount of Fire Insurance ~00,000.00 State reasons for filin!j this appeal:.~ N~ ASSESS~ IS NOT JUSTIFZ~ B~ ~N~ ~T CO~_ Property Type: Check and Complete Proper Classification: Xx Commercial: Use GOLF COURSE Gross Square Fi:. 4,_500 Owner Occupied ___yes If Leased: Annual Rent Office: Gross square Ft. Owner Occupied If Leased: Annual Rent Industrial: Total Square Ft. Square Fl. Plant Area _ Tenant Occupied Lease Type: Net____ Gross__ Square Ft. Rentable Area Tennant Occupied Date Constructed 1990 Square Ft. Rentable Area Tenant Occupied Date Constructed Square Ft. Rentable Area Owner Occupied __ If Leased: Annual Rent Combination__ Date Constructed Other: Use ___ Gross Square Ft. Owner Occupied Tenant Occupied - _ If Leased: Annual Rent Date Constructed "ATTACH LAST 3 YEARS INCOME & EXPENSE STATEMENTS OR COMPLETE THE AFl'ACHED INCOME & EXPENSE FORM" Certificate of Appeal L,'we hereby decJare my/our intention to appeal from the assessed valuation ot the property described above and do hereby verify that the statements made in this appeal are true and correct. I understand that fa[se statements herein are made subject to the penalties of t8 Pa. C.S. Section 49¢L4.,...[elating to upewqm falsification to authorities. %. -' n ~ / Signed: '~A,N~" S. YROEL];CH, PRESID]"';N~ Phone fi': (Home} Owner(s) of Recard AI~ notices of these proceedings shall be mailed to: Office Use Only Name: I~'[ARC[I$ .A I~cKNIGItT III IR~/IN & MCKNtGIfl' IFee. Address: 60 ~TEST POf'fERET S'tlt~ET CARLISLE, PA 17013 (Day/Office} (717) ?SR-408B GROSS ANNUAL INCOMES FOR 3 PRIOR YEARS 19 19 19 Projected income 100% occupied 200]- 2002-- 200-3- including value of rent-free units $ $. $. Actual income received $__ $.__ $__.__ Vacancy $__ $ .... $,_ Actual other income COLF List by Type: COUP. SE $ 9 ! 1,740 $ $ PENT $ 37,294 $ $_40,224 $ MISC. $ 3,313 $ $ 952,347~ $ $ ~887_J~ $ Total Actual Income Received $ , $ GROSS ANNUAL EXPENSES FOR 3 PRIOR YEARS 200 [ 2002 2003 Gross Annual Expenses I g ....... 19 ..... 19 Real Estate Taxes $ 2~0~, [_6_.7_J ..... $. 20,596____ $ .~2_0_~_3._0_8 FIXED Insurance 15,684 24,500 EXPENSES Land Rent Other Electricity $ 18,067 $ 23,671 $ ~2_[_,~58 'Telepl~one 7:,820 _~_6 076 .... Gas [0,046 _____ 7,8t5 Water & Sewer 1%468 16,577 J~3~ Tlash Removal 1s351 __ _j~ 216 ___~ ,81 ! Heating __ 5 ~ 86~3. __~6 982 __~8~81~ Manager's Salary OPERATIONAL Fees EXPENSES - Legal & Accounting 2[,731 6,473 8,200 Payroll Taxes 24,9 rio ? 3,4 ~ ! 22 ,-Z26 Group Insurance ~7,188 1.8,712 36,028 Advertising ~ ~_J~,_SAQ 19 Wages & Salaries ZZ(L~L~ 5~ ?? Supplies t8.352___ ~L9~792 _2.6; a 77_ Maint, & Repair 21,148 21,251 Replace. Reserve Other 2¢,8, ! 7a 253,2.0~, 330, TOTAL EXPENSES 7[0,309 $ 703,572 $ 7 9~9_L5 7~ 7 ~ $ Please IJse a(ldilJonal i)ages fi)r :my olher I'emarl~s rel:llive to the'prol)erly. s $ 38,183 $ 836~ $ $ Ilems Included In Rent I_'~1 Heating I~ Air. Cond. !~ Electricity [-I TV Cable {~ Water [_-I Carpet ~ Drapes I"'l Range L-I Refrig. L-I Dishwasher L-] Garbage Disposal L"'I Parking iTl Pool I~ Rec, Facility L-I OTHER: Lq ~ Furniture # of Furnisl~ed Units: Fumlture in Units Owned By: LTl Bldg. Owner ITl 'Ftental Co. t'"'l O~her EXHIBIT "B" Cumberland County Board of Assessment Appeals Old Cou~house One Cou~house Square Carlisle, PA 17013 (717) 240-6350 (717) 240-6354 (fax) Board of Assessment Appeals Lloyd W. Bucher R. Fred Hefelflnger Sarah Hughes BONNIE M. MAHONEY Chief Assessor STEPHEN [:). T~LEY Assistant Solicitor DECISION ORDER FROELICH & COMPANY O/O MARCUS A MCKNIGHT III ESQ IRWIN & MCKNIGHT 60 WEST POMFRET STREET CARLISLE PA 17013 MAILING DATE: July 15, 2004 PARCEL NUMBER: 40-09-0533-008. 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: 06/17/2004 DATE DECISION RENDERED: 07/15/2004 EFFECTIVE FOR TAX YEAR: DECISION RENDERED: [ ] Withdrawn By Applicant [ ] Abandoned For Failure To Appear [X] Denied - No Change [ ] Approved Review Appraiser's Changes [ ] Revised Assessment Based on Hearing [ ] Other: TOTAL VALUE FAIR MARKET CLEAN AND GREEN CLEAN AND GREEN STATUS Old Assessed Value: 2,334,360 New Assessed Value: 2,334,360 NOT APPLICABLE Any person aggrieved by the order of the Board of Assessment may appeal to the Court of Common PJeas by filing a petition in the Prothonotary's office on or before August 16, 2004. VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. ~-~'President, Froelich & Company Date: AUG'lIST 16. 2004 FROELICH & COMPANY, INC., APPELLANT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, APPELLEE CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHP and SOUTH MIDDLETON SCHOOL DISTRICT, INTERESTED PARTIES. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. : CIVIL DIVISION CERTIFICATE OF SERVICE I, Marcus A. McKnight, m, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a tree and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Stephen D. Tiley, Esq., Solicitor Cumberland County Board of Assessment Appeals Old Courthouse One Courthouse Square Carlisle, PA 17013 Edward L. Schorpp, Esq., Solicitor Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Philip H. Spare, Esq., Solicitor South Middleton Twp. School District Snelbaker, Brenneman & Spare, P.C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 Richard Mislitsky, Esq., Solicitor South Middleton Township Mistlisky & Diehl One West High Street P. O. Box 1290 Carlisle, PA 17013 By: Date: August 16, 2004 IRWIN & .McKNIGHT Marcus/A. McKm'~h¢II, E~N 60 Wes~/Pomfret Stree~/ Carlisle, PA 17013 ( (717) 249-2353 Supreme Court I.D. No. 25476 FROELICH & COMPANY, INC., ~I/P~ 1 7 ?~ f : IN THE COURT OF COMMON PLEAS OF APPELLANT, CUMBERLAND COUNTYBOARD OF ASSESSMENT APPEALS, APPELLEE CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHP and SOUTH MIDDLETON SCHOOL DISTRICT, INTERESTED PARTIES. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ORDER OF COURT AND NOW, this ~ I'~ay o~' August, 200~, a hearing in reference to the attached Petition for Appeal is scheduled for the ~day of C~7~-~, 2004, at ~,'.:~__~m. in Courtroom Number I of the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. CC: Stephen D. Tiley, Esq. Philip H. Spare, Esq. Edward L. Schorpp, Esq. Richard Mislitksy, Esq. Marcus A. McKnight, III, Esq. FROELICH & COMPANY, 1NC., Appellant CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHIP and SOUTH MIDDLETON SCHOOL DISTRICT, Interested Parties NO. 04-4075 CIVIL TERM ORDER OF COURT AND NOW, this 20~ day of October, 2004, upon agreement of counsel, Appellant's Petition for Appeal previously scheduled for October 27, 2004, is CONTINUED GENERALLY. Counsel are directed to contact the Court if they desire a hearing in this matter or if a settlement is reached. BY THE COURT, Stephen D. Tiley, Esq.. Philip H. Spare, Esq. Edward L. Schorpp, Esq. Richard Mislitsky, Esq. Marcus A. McKnight, III, Esq. :rc FROELICH & COMPANY, INC., Appellant, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee, CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHIP and SOUTH MIDDLETON SCHOOL DISTRICT, Interested Parties IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-4075 CIVIL DIVISION AND NOW, comes Cumberland County Board of Assessment Appeals, Appellee, and County of Cumberland, Interested Party, by Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters, and files this Answer, of which the following is a statement: 1. Admitted. 2. Admitted. 3. Admitted in part. Denied in part. The averments of this paragraph are admitted except that the Citation is to the Third Class County Assessment Law and the correct Citation is to Section 301 The Fourth to Eighth Class County Assessment Law (72 P.S. §5453.301). 4. Admitted in part. Denied in part. The averments of this paragraph are admitted, however, there is a typographical error in the numerical statement of the assessment, which should be $2,334,360.00. Froelich & Company, Inc. v. Cumb. Cty. Board of Assessment Appeals Page I of 3 5. Admitted. By way of further Answer, the assessment of $1,639,290.00, which was a result of the year 2000 Countywide reassessment, is irrelevant to the within appeal of the assessment fixed as a result of the year 2004 C. ountywide assessment, for taxes imposed on or after January 1, 2005. 6. Admitted. 7. Admitted. 8. Admitted. 9. Denied. The averments of this paragraph, and each and every of its sub- paragraphs, sets forth conclusions of law for which no responsive pleading is required. WHEREFORE, the County of Cumberland, ennsyl:vama, and the Cumberland County Board of Assessment Appeals, pray Your Honorable Court for an Order denying Appellant's appeal and setting the fair market value of the subject premises at $2,334,360.00. Respectfully submitted, Stephen IJ. Tile), Esquire Attorney for Respondent 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 Froelich & Company, Inc. v. Cumb. Cty. Board of Assessment Appeals Page 2 of 3 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 rrtade and subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Dated: l~onnie M. Ma]~oney, Chie~ ~s~essor ~t Froelich & Company, lnc. v. Cumb. Cty. Board of Assessment Appeals Page 3 of 3 Stephen D. Tilcy, Esquire Frey and Tiley Attorneys for Respondent Cumberland County Tax Claim Bureau 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717-243-5838 Fax.: 717-243-6441 FROELICH & COMPANY, INC., Appellant, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee, CUMBERLAND COUNTY, SOUTH MIDDLETON TOWNSHIP and SOUTH MIDDLETON SCHOOL DISTRICT, Interested Parties IN THE COURT OF COMMON PLEAS OF CUMBERLAND ,COUNTY, PENNSYLVANIA No. 2004-4075 CIVIL DIVISION 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: Marcus A. McKnight, III, Esquire Attorney for Appellant IRWIN & MCKNIGHT 60 West Pomfret Street Carlisle, PA 17013 Philip H. Spare, Esquire South Middleton School District SNELBAKER, BRENNEMAN & SPARE 44 West Main St., P.O. Box 318 Mechanicsburg, PA 17055 Date: Richard P. Mislitsky, Esquire South Middleton Township MISL1TSKY & DIEHL One West High St., Suite 208 P.O. Box 1290 Carlisle, PA 17013 ~tepht(n D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attomey I.D.#32318 Stephen D, Tiley, Esquire Frey and Tiley Attorneys for Respondent Cumberland County Board of Assessment Appeals 5 South Hanover Street Carlisle, Pennsylvania 17013_ Supreme Court No. 32318 Td,; 717-243-5838 Fax,; 717-243-644\ FROELICH & COMPANY, INC., Appellant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2004-4075 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, CIVIL DIVISION Appellee, v. CUMBERLAND COUNTY, SOUTH MIDDLETON SCHOOL DISTRICT, Interested Parties ORDER L Zo~ AND NOW, this l~ 1 day of fe1,. , AOO4, upon consideration of the within Stipulation and Joint Motion for Agreed Order, it is Decreed and Ordered that the total market value of the subject property (tax parcel number 40-09-0533-008) as of the date applicable to this proceeding, is $1,900,000,00, As a result of the year 2004 Countywide reassessment, effective January 1, 2005, the common level ratio is not applicable to said r,eassessment which shall be fixed at the new predetermined rate of 100% of year 2004 value. The total assessment of the property for tax years beginning on and after January 1, 2005, and thereafter until changed as provided by law, shall be $1,900,000.00. The Cumberland County Assessment Office shall allocate said total assessment between land and improvements as provided by law, and by the procedures of the Cumberland County Assessment Office. The Cumberland County Assessment Office shall promptly notify the appropriate taxing bodies of the change in assessment. BY THE COURT By: /) /1 /oA:. , :ft. J. or, 3; :2 !lJ , z.. r-o ,'~ c ":l '::U(~-~ Stephen D. Tiley, Esquire Frey and Tiley Attorneys for Respondent Cumberland County Board of Assessment Appeals 5 South Hanover Street Carlisle, Pennsylvania 17013 Supreme Court No. 32318 Tel.: 717-243-5838 Fax.: 717-243-6441 FROELICH & COMPANY, INC., Appellant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. No. 2004-4075 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, CIVIL DIVISION Appellee, v. CUMBERLAND COUNTY, SOUTH MIDDLETON SCHOOL DISTRICT, Interested Parties STIPULATION AND .JOINT MOTION FOR AGREED ORDER AND NOW, this d.?"""?day of December, 2004, it is hereby Agreed and Stipulated between Petitioner/Appellant, Froelich & Company, Inc., by its Attorneys, Irwin & McKnight; and Respondent/Appellee Cumberland County Board of Assessment Appeals, by its Attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters; and Interested Party, South Middleton School District, by it Attorneys, Stock and Leader, LLP, and is as follows: 1. Petitioner/Appellant filed a Petition for Appeal on August 16, 2004, to which an Order was entered on August 18, 2004 fixing a Hearing date of October 27, 2004. On October 20,2004, the Hearing originally scheduled for October 27,2004 was continued generally. On October 26, 2004 Respondent/Appellee filed an Answer. The parties have now settled this case Stipulation and Joint Motion For Agreed Order Froelich & Co., Inc. vs. Cumbo Co. Board 01 Assessment Appeals page 1 013 2. This Assessment Appeal relates to the value of the subject property as a result of the year 2004 Cumberland County, countywide, reassessment, effective for assessments beginning on and after January 1,2005. 3. The property which is the subject of this appeal is Cumberland County Assessment Parcel No. 40-09-0533-008 and is known as the Mayapple Golf Links and Restaurant property, situate in South Middleton Township, Cumberland County, Pennsylvania. 4. The parties stipulate that the total fair market value of the subject property as of the date of the original Petition to the Cumberland County Board of Assessment Appeals is $1,900,000.00. 5. As a result of the year 2004 Cumberland County Countywide reassessment, the predetermined ratio is now 100% of the year 2004 value. The common level ratio is inapplicable because it does not vary by more than 15% of the previous predetermined ratio, and as it has not been published yet for the 2004 reassessment. Therefore, the assessment shall be fixed as of January 1,2005 at $1,900,000.00. 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 $1,900,000.00 assessment shall be effective for tax years beginning on and after January 1,2005 and shall remain unchanged unless and until changed as otherwise provided by law, and shall be implemented beginning with the 2005 county and municipal taxes and beginning with the 2005-06 school real estate taxes. 8. The Cumberland County Assessment Office shall promptly notify that appropriate taxing bodies of the change in assessment, and instruct the taxing bodies to make any appropriate refunds. 9. Each party to this appeal shall bear its own costs. Stipulation and Joint Motion For Agreed Order Froelich & Co., Inc. vs. Cumbo Co. Board of Assessment Appeals page20f3 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 has reviewed this Settlement Stipulation with his client or clients and that he has specifically been authorized to enter into this Settlement Stipulation by his client or clients. Respectfully Submitted, PETITIONER, FROELICH & COMPANY, lNe. BY~ ( Marcus ~ c night, , IRWIN MCKNIGHT 60 West . Carlisle, PA 17013 Attorney for Petitioner RESPONDENT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS BY .~~.4y7~ teph D. TIley, EsqUIre Assistant Cumberland County Solicitor for Tax Matters Attorney for Respondent 5 South Hanover Street Carlisle, PA 17013 tel #(717) 243-5838 (Supreme Court ID# 32318 INTERESTED PARTY, SOUTH MIDDLETON SCHOOL DISTRICT BY:~tI5?~ Philip H. Spare, Esquire Stock and Leader, LLP Attorney for South Middleton School District Susquehanna Commerce Ctr. East 221 W. Philadelphia St., 6th Floor York, PA 17404 Stipulation and Joint Motion For Agreed Order Froelich & Co.. Inc. VS. Cumb, Co. Board of Assessment Appeals page 3 013