Philadelphia BRT Ruling Applies Reduced CLR Values to Property Assessments

January 2012Alerts Tax Appeals Practice Alert

In a case of first impression, the City of Philadelphia’s Board of Revision of Taxes (BRT) decided on January 19, 2012, to apply the new City of Philadelphia Common Level Ratio (CLR), which had been reduced by Pennsylvania’s State Tax Equalization Board (STEB) from 32 percent to 18.1 percent, to property values as certified by the City of Philadelphia’s Office of Property Assessment (OPA), a ratio that could cut property taxes some 44 percent.

In this matter, taxpayer Race Parking Associates (Race Parking) filed a tax appeal but did not dispute the market value certified by the OPA. Rather, Race Parking asked the BRT to apply the CLR.

This BRT ruling is likely to be appealed to the Court of Common Pleas. The new CLR is already the subject of a separate appeal filed by the County of Philadelphia. We are cautiously optimistic that the BRT will continue to apply the newCLR to property values as certified by theOPA but recognize that this issue will be the subject of contentious litigation.

For more information, please contact Jeffrey M. Herskowitz , William F. Martin or Christopher C. Fallon, III or any member of the firm's Real Estate Department.