Tax Assessment Appeal on Commercial Properties In Pennsylvania

In re Springfield School District, 879 A.2d 335 (Pa. Cmwlth. 2005), this Court held a property's revaluation initiated by a school district's appeal did not violate the uniformity or equal protection clauses. There, a local school district filed tax assessment appeals on two commercial properties, which the Board denied. The trial court concluded the school district's methodology for the selection of tax assessment appeals, which focused almost entirely on commercial properties, was arbitrary and capricious, and the methodology violated tax uniformity and equal protection guarantees. On appeal, this Court reversed. The Court determined the statutory appeal powers under Section 18 of the Second Class a and Third Class County Assessment Law were identical to those discussed in Vees. The Court also discerned no statutory limit on the method used by property owners or school districts to select which assessments to appeal. The Court concluded an appeal pursuant to Section 18 does not amount to deliberate, purposeful discrimination as a matter of law.