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HomeMy WebLinkAbout04-5641SILVER SPRING COURTYARDS IN THE COURT OF COMMON PLEAS Appellant OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. No.. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS Respondent APPEAL FROM ASSESSMENTS OF THE BOARD OF ASSESSMENT APPEALS ON THIS, the day of November 2004, your Appellant, SILVER SPRING COURTYARDS, by its attorneys, respectfully appeal from the tax assessment of the Board of Assessment Appeals and in support thereof assert that: 1. Appellant is Silver Spring Courtyards, 146 Pine Grove Circle, Suite 200, York, PA 17403. 2. Respondent is the Cumberland County Board of Assessment Appeals (hereinafter 'Board"). 3. Silver Spring Courtyards is the owner of the premises located at 43 Ashburg Drive, Silver Spring Township, Cumberland County, Pennsylvania, being Parcel No. 38-18- 1342-200 on the records of the Assessment Office of Cumberland County. 4. The Tax Assessor for the assessment district in which the subject parcel is located has assessed the premises for taxation effective 1/1/2005 at the total of $2,744,000. {0013137011) 5. Silver Spring Courtyards appealed said assessment to the Board for relief asking that the assessment be reduced. 6. The Board did not reduce the assessment of the subject parcel. 7. Silver Spring Courtyards was notified of such denial of the reduced assessment by letter dated October 14, 2004, a copy of which is attached hereto as Exhibit "A" and made a part hereof. 8. The assessment of the subject property, Parcel No. 38-18-1342-200, known as 43 Ashburg Drive, is inequitable, unjust, and contrary to law for the following reasons: A. The assessment lacks uniformity with other commercial properties within the taxing district as required by law. B. The Board failed to accurately apply the common level ratio established by Act 267 of 1982. C. The assessment is based upon an appraisal of the parcel that is excessively high and does not accurately represent the fair market value of the land or of the improvements thereon. D. The assessment fails to follow the directive of House Bill No. 1854, Session of 2003, signed into law by the Governor of Pennsylvania on December 2, 2003 requiring that for purposes of determining the valuation of property and arriving at the assessment, the impact of applicable rent restrictions, affordability requirements or any other related restrictions proscribed by any Federal or state programs should be considered and that Federal or state income tax credits with respect to the property shall not be considered real property or income attributable to real property. The current assessed value represents a valuation determined without regard to the aforementioned law and therefore requires that the assessed value be changed to reflect the new law, effective as of December 3, 2003 in accordance with the law's mandate that the Act should take effect immediately upon execution by the Governor. 9. The Appellant is aggrieved by the assessment and has the right to appeal therefrom pursuant to the General County Assessment Law and the Third Class County Assessment Law. {0013137011} WHEREFORE, your Appellant asks this Court to hear this Appeal and to reduce the assessment on Parcel 38-18-1342-200 to $2,195,200 in the aggregate in addition to such other relief as the Court deems appropriate and just. CGA LAW FIRM By. _.e:, Ronald Perry Supreme Court No. 28362 29 North Duke Street York, PA 17401 Telephone: 717-848-4900 Attorneys for Appellant {00131370/1} CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing Appeal from Assessments of The Board of Assessment Appeals was served on Defendant's counsel in the manner indicated below: FIRST-CLASS MAIL POSTAGE PREPAID THEREON ADDRESSED AS FOLLOWS: Stephen D. Tiley Solicitor, Cumberland County Assessment Office 5 South Hanover Street Carlisle, PA 17013 Steven Stine Solicitor for Silver Spring Township 23 Waverly Drive Hummelstown, PA 17036 Jerry R. Duffle Solicitor for Cumberland Valley School District Johnson, Duffie, Stewart & Weidner P.O. Box 109 301 Market Street Lemoyne, PA 17043 By: A46 7 Dated: K)O1 51 11;?Goli (00131370/1) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. We, the undersigned Appellant, SILVER SPRING COURTYARDS, who being duly sworn according to law, depose and say that the facts set forth in the foregoing Appeal are true and correct to the best of their knowledge, information and belief Sworn and Subscribed to before me this .2S- day of QG? 6'e'r- 2004. Notary Pub c SILVER SPRING COURTYARDS By: ! ?R V?s, 6 ?. r- j .S' ?L JER sPKni 6 CL'x?'?,'H?'-?S Lt? COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Bunnell, Notary Public City Of York, York County My Commission Expires Feb. 5, 2008 Member, Pennsylvania Association Or Notaries {00131370711 EXHIBIT "A" {0013137011} Cumberland County Board of Assessment Appeals Old Courthouse One Courthouse Square Carlisle, PA 17013 Board of Assessment Appeals Lloyd W. Bucher R. Fred Hefelfinger Sarah Hughes DECISION ORDER SILVER SPRING COURTYARDS C/O RONALD PERRY 29 NORTH DUKE STREET YORK PA 17401 Dear Property Owner: (717) 240-6350 (717) 240-6354 (fax) BONNIE M. MAHONEY Chief Assessor STEPHEN D. TILEY Assistant Solicitor MAILING DATE: October 14, 2004 PARCEL NUMBER: 38-18-1342-200. 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: 10/05/2004 DATE DECISION RENDERED: 10/1412004 EFFECTIVE FOR TAX YEAR: 2005 DECISION RENDERED: [ ] 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: 2,227,970 New Assessed Value: 2,744,000 NOT 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 15, 2004. VERIFICATION We verify that the statements made in this Appeal from Assessment of the Board of Assessment Appeals are correct. We understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Dated: io b-5- SILVERS G COURTYARDS By: L, Ve/t 5PR1/06- [our?rifl ?StP {00131370/1} 44 ,-t I TP SILVER SPRING COURTYARDS, APPELLANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, RESPONDENT 04-5641 CIVIL TERM ORDER OF COURT AND NOW, this day of November, 2004, IT IS ORDERED that a hearing shall be conducted on the within assessment appeal in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania on Wednesday, February 9, 2004, at 9:00 a.m. By Edgar B ,,.,Ronald Perry, Esquire 29 North Duke Street York, PA 17401 For Appellant phen D. Tiley, Esquire Solicitor, Cumberland County Assessment Office ,,even Stine, Esquire Solicitor, Silver Spring Township Aerry D. Duffie, Esquire Solicitor, Cumberland Valley School District :sal l.? ' ti.w+ °r E ~ 1? 1.1.. ?{? ....?. _ _- I ? ? ..a" cr:-? ? --? ?..? C:? 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 SILVER SPRING COURTYARDS, . IN THE COURT OF COMMON PLEAS OF Appellant CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, 2004-5641 CIVIL TERM Respondent ANSWER AND NOW, comes Respondent, Cumberland County Board of Assessment Appeals and County of Cumberland 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. See also paragraph 3 of this Answer. 2. Admitted. 3. Admitted in part. Denied in part. The averments of this paragraph are admitted, however, the Cumberland County assessment records indicate that the owner of Parcel No. 38-18- 1342-200 is "Silver Spring Courtyards, L.P." of 18 South George Street, No. 425, York, Pennsylvania 17400, and the Board appeal form filed by the taxpayer in this case lists the Appellant as "Springwood Real Estate Services" at the address set forth in paragraph one of Appellant's Petition. 4. Denied. The Cumberland County Assessment Office, as part of the 2004 countywide reassessment, assessed the property which is the subject of this appeal at $2,227,970.00. That assessment is based upon the standard computer models used for the countywide reassessment. Appellant appealed that assessment to the Cumberland County Board of Assessment Appeals. A that time the Cumberland County Assessment Office prepared a new valuation, more specifically prepared for the subject property, and recommended a value of $3,157,500.00. At that Hearing the Board set the market value of $2,744.000.00. The within ANSWER - Silver Spring Courtyards Page 1 of 3 appeal being to Cumberland County Court, it is de novo and the technical assessment appealed to the Court is the original countywide reassessment figure of $2,227,970.00. 5. Admitted. 6. Admitted. By way of further Answer the Board increased the assessment as shown on the Decision set forth at Exhibit "A" to delay Appellant's Petition, and as described in paragraph 4 of this Answer. 7. Admitted. By way of further Answer, see paragraph's 4 and 6 of this Answer. 8. Denied. The averments of this paragraph, and each of its sub-lettered paragraphs, are denied as conclusions of law to which no responsive pleading is required. 9. Admitted. (Except that the Appellant's right to appeal is pursuant to § 518.1 of The General County Assessment Law (72 P.S. § 5020-518.1) and § 704 of The Fourth to Eighth Class County Assessment Law (72 P.S. §5453.704) and not the Third Class County Assessment Law as stated by Appellant.) WHEREFORE, Respondent, Cumberland County Board of Assessment Appeals, and County of Cumberland, prays Your Honorable Court for an Order denying Appellant's appeal and fixing the assessment of the subject parcel at $2,744,000.00 or such higher amount as the Court may deem just and proper. Dated: Gl?r'? o23v?/ Respectfully submitted, n '' ?`%L S By??,,, G? r Stephen D. `i'iley, Esquire Attorney for Respondent 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 ANSWER - Silver Spring Courtyards Page 2 of 3 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. Dated: I'Of Bonnie M. Mahoney, Ch? A/ ief As ssor ANSWER - Silver Spring Courtyards Page 3 of 3 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 SILVER SPRING COURTYARDS, Appellant V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2004-5641 CIVIL TERM 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: Ronald Perry, Esquire Attorney for Appellant 29 North Duke Street York, PA 17401 Steven A. Stine, Esquire Solicitor for Silver Spring Township 23 Waverly Drive Hummelstown, PA 17036 Jerry R. Duffie, Esquire Solicitor for Cumberland Valley School District Johnson, Duffie, Stewart & Weidner P.O. Box 109 Lemoyne, PA 17043 Date: "/ G Sfephen D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D.#32318 n v C) CA v - -q7 im >' 4 ii1 1 ., , - , GJ C_, 0 1 1, J )rn Q Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for Respondent Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel.: 717-243-5838 Carlisle, Pennsylvania 17013 Fax.: 717-243-6441 SILVER SPRING COURTYARDS, : IN THE COURT OF COMMON PLEAS OF Appellant . CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD : OF ASSESSMENT APPEALS, Respondent ORDER AND NOW, this 2004-5641 CIVIL TERM of February, 2005, upon representation by Stephen D. Tiley, Esquire, counsel for the Respondent, that the Petitioner and Respondent have agreed to request a general continuance of this matter, the Hearing previously scheduled for February 9, 2005 is cancelled and the matter is CONTINUED GENERALLY at the call of either party. cc: Ko ld Perry, Esquire teven A. Stine, Esquire )e6 R. Duffle, Esquire oa- ? 03 ORDER - Silver Spring Courtyards page 1 of 1 4''''' ? ? fi ;1i 4 -? r} ?, ?.? Ui'':. rt ? ?'i vim.-.'$ £ ?'?_ - ?, __ .u. .,... :'I ORIGINAL Richard P. Nuffort, Esquire Attorney I.D. No. 16044 Zimmerman, Pfannebecker, 22 South Duke Street Lancaster, PA 17602 (717) 299-0711 Nuffort & Albert, LLP SILVER SPRING COURTYARDS IN THE COURT OF COMMON PLEAS Appellant OF CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD OF 2004-5641 CIVIL TERM OF ASSESSMENT APPEALS, Responent PRAECIPE TO WITHDRAW AND ENTER APPEARANCE Please withdraw the appearance of Ronald Perry, Esquire, of the law firm of Katherman, Heim & Perry as attorney for the Appellant in the above-referenced tax appeal. /1' ?-7 Date: KATHERMAN, HEIM & PERRY By: lk?P lze?` Ronal ; is e Please enter the appearance of Richard P. Nuffort, Esquire, of the law firm of Zimmerman, Pfannebecker, Nuffort & Albert as attorney for the Appellant in the above- referenced tax appeal. Date: ZIMMERMAN, PFANNEBECKER, NUFFO ALBERT LLP (J'q By: Richard P. Nuffo , Esquire Attorney for Appellant 220-07N 4/13/07 V? -v `i Stephen D. Tiley, Esquire Supreme Court No. 32318 Frey and Tiley Attorneys for Respondent Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel.: 717-243-5838 Carlisle Pennsylvania 17013 Fax.: 717-243-6441 SILVER SPRING COURTYARDS, : IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD : OF ASSESSMENT APPEALS, : 2004-5641 CIVIL TERM Respondent STIPULATION AND JOINT MOTION FOR AGREED ORDER AND NOW, this day of July, 2008, it is hereby Agreed and Stipulated by and between Petitioner, Silver Spring Courtyards, by its attorneys, Zimmerman, Pfannebecker, Nuffort & Albert, LLP; and Respondent, Cumberland County Board of Assessment Appeals, by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters; as follows: 1. Petitioner filed an "Appeal from Assessments of the Cumberland Board of Assessment Appeals" on November 9, 2004, to the above captioned term and number. The case was continued generally by Order dated February 4, 2005. The parties have now settled this case. 2. This assessment appeal relates to the market value as of July 30, 2004, the date the appeal was originally filed before the Board of Assessment Appeals, effective for assessments beginning on and after January 1, 2005, and for each succeeding year thereafter. The parties further stipulate and agree that this case shall be deemed a Stipulation and Joint Motion for Agreed Order Page 1 of 5 Silver Spring Courtyards continuing appeal for the 2009 calendar year, and that the assessments fixed hereunder shall be applicable for said year 2009. 3. The property which is the subject of this appeal consists of a 55-unit affordable housing rental complex, financed, in part, with low income tax credits. The property is situate at 39-43 Ashburg Drive, Silver Spring Township, Cumberland County, Pennsylvania 17050, and is known as Cumberland County Tax Parcel No. 38-18-1342- 200. The property is further known as the Silver Spring Courtyards apartment complex. 4. The parties stipulate that the total fair market value of the property as of the date of the original appeal to the Board of Assessment Appeals, July 30, 2004, and for each valuation date thereafter, through and including July 30, 2008 for the 2009 effective year, together with the resulting assessment, is as follows: Valuation Date Year Applicable Fair Market Value 7/30/04 2005 $1,925.000 7/30/05 2006 $1,925,000 7/30/06 2007 $1,925,000 7/30/07 2008 $1,925,000 7/30/08 2009 $1,925,000 Assessment $1,925,000 $1,925,000 $1,925,000 $1,578,500 $1,526,525 5. As a result of the year 2004 Cumberland Countywide reassessment, the predetermined ratio for all times applicable to this appeal is 100% of year 2004 market Stipulation and Joint Motion for Agreed Order Page 2 of 5 Silver Spring Courtyards value. The predetermined ratio is used in arriving at the assessment for years 2005, 2006, and 2007. The common level ratio has not varied by more than 15% from the predetermined ratio until the common level ratio published in June of 2007, effective for tax year 2008, which common level ratio was 82%. Therefore, for year 2008, the assessed value is arrived at by application of an 82% common level ratio to the stipulated fair market value. The common level ratio published in June of 2008 applicable for the 2009 tax year is 79.3%. Therefore, the assessment for year 2009 is arrived at by application of that common level ratio to the stipulated fair market value. 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 said assessment shall be effective for tax years beginning on and after January 1, 2005, and shall be as set forth in paragraph four (4) of this Stipulation, and shall continue thereafter unless and until changed as otherwise provided by law (including the current countywide reassessment.) The assessments shall be implemented beginning with 2005 County and Township taxes, and beginning with 2005/06 school real estate taxes. The ending implementation of this stipulated assessment shall be with 2009 County and Township taxes, and 2009/10 school taxes, on the assumption that the property is revalued effective January 1, 2010, as a result of the current Cumberland County countywide reassessment. In the event of new construction, or demolition, affecting an assessment after the date hereof but on or before December 31, 2009, this Stipulation and Joint Motion for Agreed Order Page 3 of 5 Silver Spring Courtyards 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, PETITIONER, SILVER SPRING COURTYARDS By P-* - I - - - Richard P. Nuffort Esqu' e Attorney for Petitioner Zimmerman, Pfannebecker, Nuffort & Albert, LLP 22 South Duke Street Lancaster, PA 17602 Stipulation and Joint Motion for Agreed Order Page 4 of 5 Silver Spring Courtyards RESPONDENT CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS BY v Stephen D. Tiley, Esquire Assistant Cumb. Cty. Solicitor for Tax Matters Attorney for Respondent Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel No. (717) 243-5838 Supreme Court ID# 32318 Stipulation and Joint Motion for Agreed Order Page 5 of 5 Silver Spring Courtyards N N N 0 JAN 13 2009(x, SILVER SPRING COURTYARDS, : IN THE COURT OF COMMON PLEAS OF Petitioner . CUMBERLAND COUNTY, PENNSYLVANIA V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, 2004-5641 CIVIL TERM Respondent ORDER AND NOW, this A-710 day of , 2 upon consideration of the Stipulation and Joint Motion for Agreed Order, it is DECREED and ORDERED that the total assessment for the property known as Silver Spring Courtyards (Parcel No. 38-18-1342-200) situate in Silver Spring Township, Cumberland County, Pennsylvania, shall be as follows: Valuation Date Year Applicable Fair Market Va lue Assessment 7/30/04 2005 $1,925.000 $1,925,000 7/30/05 2006 $1,925,000 $1,925,000 7/30/06 2007 $1,925,000 $1,925,000 7/30/07 2008 $1,925,000 $1,578,500 7/30108 2009 $1,925,000 $1,526,525 The said assessments shall continue thereafter until changed as provided by law. The Cumberland County Assessment Office shall allocate the said assessments between land and improvements, in accordance with law and the procedures of the Cumberland County Assessment Office. The said Stipulation and Joint Motion for Agreed Order is incorporated herein. SDT/tl cc: and P. Nuffort, Esquire, for Silver Spring Courtyards phen D. Tiley, Esquire, Assistant Cumberland County Solicitor ., a Ski / R? b ORDER - Silver Spring Courtyards Page I of 1 CC) tom} Z! r l Q ? N