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Property Tax Resources

Each quarter our members take a close look at their local counties and municipalities and review any changes or notable events in the areas of property taxes, tax assessments, personal property tax and other taxation issues, here is the most recent local tax update available.

Jan
01

Alabama Property Tax Updates

UPDATED June 2024

Alabama Legislature Passes 7% Annual Cap

The Alabama legislature recently enacted a bill (HB73) that will establish a 7% cap on annual increases in assessed values for most real property parcels in the State.

The cap will go into effect beginning with the 2025 tax year (valuation date as of 10/1/24). The 7% cap shall not apply to: (i) real property that has never been assessed, (ii) new additions and improvements, excluding repairs and ordinary maintenance, (iii) changes in classification, (iv) changes in ownership, excluding some family transfers and redemptions, and (v) properties located within a tax increment district.

The cap legislation has a sunset provision of three years, meaning that the legislature must renew the legislation to extend the cap beyond the 2027 tax year.


Aaron D. Vansant, Esq.
DonovanFingar, LLC
American Property Tax Counsel (APTC)

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Jan
01

California Property Tax Updates

UPDATED march 2025

California Supreme Court to Hear Olympic & Georgia Case Within the Next Couple Months

The California Supreme Court is scheduled to hear oral arguments in the Olympic & Georgia Partners LLC v. County of Los Angeles case no later than June 6, 2025.  This is the latest in a string of California appellate court cases dealing with the removal of non-taxable intangibles in the valuation and assessment of hotel and hospitality properties.  The Court of Appeal below held that the assessment on a convention hotel should have been reduced by the value of the intangible assets.  Specifically, the Court of Appeal determined that the County incorrectly assessed the hotel under the income method by including income from three non-taxable intangible assets/rights:  (1) an $80 million transient occupancy tax subsidy from the City of Los Angeles; (2) a $36 million fee discount provided by the hotel management company to the owner; and (3) $34 million in hotel enterprise assets.  Because the non-taxable intangibles directly contributed to the hotel’s success and could be quantified, the County (and the Board) erred in including the intangibles’ values in their valuation.  Olympic & Georgia Partners may be the next seminal case on California’s treatment of intangible assets in the property tax arena.  The Supreme Court’s decision will be of interest to tax attorneys in California and other states as the courts continue to wrangle with the issue of excluding non-taxable intangibles from assessment. 

Cris K. O'Neall and Bree E. Burdick
Greenberg Traurig, LLP
American Property Tax Counsel (APTC)

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Jan
01

Connecticut Property Tax Updates

Updated september 2024

Connecticut Real Estate Tax Update: 2024 Municipal Revaluations in Connecticut – Is Your Town Among Them?

It is always important to carefully review your tax bill and/or notices of assessments, but even more so in the year in which your city or town conducts a revaluation.

Each assessment should be carefully reviewed, even if your assessment has not increased substantially, as an appeal immediately after a revaluation maximizes a property owner's potential tax savings.

Connecticut law requires that each municipality conduct a general revaluation of the real estate within its borders at least once every five years. Given the passage of Connecticut Public Act 22-74, the State's Revaluation Schedule has shifted slightly with the creation of five new Revaluation Zones which purportedly allows for the coordination of revaluation services and provides a mechanism to create efficiency and municipal cost savings. This new law does not change the fact that municipalities must conduct revaluations in Connecticut every five years, however, the result is that some municipal revaluations are a year shorter or longer to transition into the new schedule.

The purpose of a revaluation is for a municipality to determine the market value of real estate to be used to calculate property taxes.

Once a property's value is set in a general revaluation, it remains constant over the entire five-year cycle, absent appeal, demolition, improvements or expansion. Of course, the annual taxes usually increase, as a municipality's mill rate increases incrementally from year to year. Municipalities across the State are on differing revaluation cycles.

The following is a list of Connecticut municipalities conducting revaluations this year:

Bloomfield
Branford
Brooklyn
Canterbury
Coventry
Hamden
Mansfield
Monroe
New Fairfield
North Branford
North Haven
Old Lyme
Oxford
Pomfret
Prospect
Putnam
Seymour
Thompson
Tolland
Torrington
Voluntown
Wallingford
West Haven
Windsor Locks*
Woodbridge

*One-year delay as Revaluation was originally scheduled for 10/1/2023

If your municipality is conducting a general revaluation for the October 1, 2024 Grand List you will receive a notice of tax assessment change soon.

Once the notices are issued, there may be a chance to meet informally with the assessor to discuss the new assessment, which should represent 70% of the fair market value of your real estate. However, if a property owner wishes to challenge the assessment formally, a written appeal must be filed with the local Board of Assessment Appeals by the February 20, 2025 statutory deadline.

It is in your best interest to be proactive in monitoring the revaluation process and your new assessment so that you can take all necessary steps to ensure that the assessment is equitable.


Nicholas W. Vitti Jr. and Joseph D. Szerejko
Murtha Cullina LLP
American Property Tax Counsel (APTC)

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Jan
01

Florida Property Tax Updates

UPDATED march 2024

Live Local: Property Tax Exemption for the “Missing Middle”

A new property tax exemption signed into law in March 2023 has garnered significant attention from multifamily developers. The property tax exemption is referred to colloquially as the “Missing Middle” property tax exemption because its aim is to encourage development of workforce housing to serve people with incomes above those served by traditional affordable housing, but still priced out of the very high rental market.

The exemption has two levels. There is a 100% exemption for units rented to tenants whose income is at or below 80% of the area median income, commonly known as AMI, and a 75% exemption for units rented to tenants whose income is between 80% and 120% AMI. To qualify for the exemption, multifamily projects must have at least 71 units meeting the restrictions and must have been built within the past five years. Rents must be the lesser of 90% of market rent for the area in question or the rental limits prescribed by HUD annually. Counties administer the exemption on a unit-by-unit basis, but the proportionate value of the land and common elements are also exempt.

The law passed in 2023 and first applies to the 2024 tax year.  With such a quick roll-out, many details remain to be worked out and changes were already made in the 2024 legislative session.  For example, a  new bill passed in March 2024 allowing  counties to opt out of the 75% exemption if the number of available units catering to tenants at or below 120% AMI exceeds the number of households in the county at or below 120% AMI.   Changes and clarification will certainly continue to be made as this exemption is first applied this year.


Julie Schwartz and Daniel Wolfe
Rennert Vogel Mander & Rodriguez, P.A.
American Property Tax Counsel (APTC)

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Jan
01

Georgia Property Tax Updates

UPDATED march 2025

Watch Your Appeal Deadlines in Georgia

It’s almost that time of year again in Georgia – time to start thinking about ad valorem property tax appeal filing deadlines. County tax assessors mail out assessment notices to all real property owners in Georgia in the April/May/June time frame. Be on the lookout for assessment notices for each parcel owned. Appeals must be filed within 45 days of the date of the assessment notice. If you fail to meet this deadline, it will be too late to appeal when you get your tax bill and are dissatisfied with the amount of taxes you owe.


Lisa F. Stuckey
Georgia Property Tax Counsel, LLC
American Property Tax Counsel (APTC)

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Jan
01

Kentucky Property Tax Updates

UPDATED march 2025

Derby Time is Appeal Time

For most people in Kentucky, early May means it’s time for the Kentucky Derby – but for property owners, May means that it’s time to review real property tax assessments for possible appeal.

Kentucky property is assessed as of January 1st of each year.  A property owner wishing to challenge an assessment must follow the requirements for conferences and appeals.  The first step in challenging an assessment is to request a conference with the county property valuation administrator (PVA).  Kentucky law mandates that all conferences must be held during (or before) a two-week period beginning the first Monday in May.  A taxpayer who fails to request a PVA conference within the statutory timeframe is barred from any further assessment appeals for that tax year.

PVAs are required to send taxpayers written notice of any assessment increase; however, notice is not required when the assessment did not increase.  Taxpayers may appeal their assessment, regardless of whether there was an increase – but it is up to the taxpayer to determine the applicable deadlines and to make the requisite request for a conference.

While assessment notices may go out any time before the statutory appeal period, most counties do not finalize their assessments until mid to late April.

If you have a Kentucky property that you think is overassessed, now is the time to start thinking about an appeal.  The appeal window is easy to miss, and it is open for a very short time.

Michele M. Whittington
Morgan Pottinger McGarvey
American Property Tax Counsel (APTC)

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Jan
01

Massachusetts Property Tax Updates

UPDATED december 2022

Massachusetts Fiscal Year 2023 Property Tax Bills are to be issued

Most jurisdictions in Massachusetts sent out there actual fiscal year 2023 property tax bills during December of 2022.  The actual property tax bill is the first tax bill of the fiscal year that contains as assessed value and a tax rate. It is from this actual property tax bill that rights of appeal accrue. In most cases the fiscal year 2023 filing deadline is February 1, 2023. It is important to review your actual property tax bill as many communities in the Commonwealth are revaluing. In most cases the timely payment of property taxes is a jurisdictional prerequisite to a valid property tax appeal. Timely payment means that payment must be mailed to the tax collector by the due date. It is incumbent on the taxpayer to prove the date of mailing. Taxpayers must be vigilant as the taxing authority has the advantage at every turn.

David G. Saliba
Saliba & Saliba
American Property Tax Counsel (APTC)

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Jan
01

Michigan Property Tax Updates

UPDATED December 2024

Coming Soon: 2025 Michigan Assessment Notices & Tax Appeal Deadlines

During the first quarter, Michigan assessors will be sending 2025 assessment notices.  For some properties, including those real property parcels that assessors have classified as agricultural or residential, an appeal to the Michigan Tax Tribunal usually requires first satisfying appeal requirements at the local level.

 Michigan’s inflation cap for taxable values (on which taxes are based), will be 3.1% for 2025.  When combined with the 5% increases of 2023 and 2024, some properties will be suffering from 13% plus tax increases during a relatively short period in which cap rates for many properties have increased and property values have declined.   

For Michigan properties that the assessors have classified as commercial real or industrial real, taxpayers should calendar May 31 as the appeal deadline for valuation appeals notwithstanding that the deadline is extended to the following Monday because May 31, 2025 is a Saturday.  Those with property tax concerns, whether because of a valuation, exemption or other issue, should confer with their property tax counsel as soon as reasonably possible.

Recent Michigan Appellate Decisions Make Property Transaction Planning More Important Than Ever.

Earlier this year, we mentioned the importance of property tax due diligence for those seeking to acquire Michigan property.  Since raising this matter, the Michigan Court of Appeals has issued more decisions that make this more important than ever.  Each year there are taxpayers who acquire properties and agree to purchase prices without carefully estimating what will happen to property taxes the year after the acquisition.  That can be a serious problem, so do not ignore a property tax risk if you will be purchasing Michigan real estate in 2025.

Michigan Court of Appeals Expands Protections For Confidential Taxpayer Information

In recent years, the Michigan Tax Tribunal has ruled that its ability to protect confidential taxpayer information was limited to narrow Michigan Freedom of Information Act exemptions.  In one of 2024’s most favorable decisions for taxpayers, the Michigan Court of Appeals has invalidated that position.  The Court held that the Tax Tribunal’s “unique position as a quasi-judicial agency with exclusive jurisdiction over tax appeal proceedings implies that information in” its possession is protected under a court rule, MCR 2.302(C)(8), which provides broad protections.  Going forward, property owners will be in a much better position to protect their confidential commercial information in Tax Tribunal appeals.   

Jackie Cook, Mark Hilpert, Stewart Mandell, Dan Stanley
Honigman LLP
American Property Tax Counsel (APTC)

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Jan
01

Nevada Property Tax Updates

Updated march 2022

Recapture Tax: The Exception To Nevada’s Tax Cap

Historically, property taxes were calculated by simply multiplying the taxable value of a parcel by the assessment rate and multiplying the resulting product by the tax rate.  This simple approach provided a level of uniformity, but in a rising market the increase in a property owner’s taxes would mirror the increase in the value of the property owner’s parcel.  A real estate market that continues to rise, year-after year, would cause taxes to escalate, squeezing those living on a fixed income.  To address this problem, the Nevada Legislature passed a partial abatement from property tax which applies to all properties.  This legislation is commonly referred to as the tax cap because it limits the amount taxes can increase, from one year to the next, to a fixed percentage.  This ensures predictability and stability in the tax treatment of a parcel – unless the valuation of the parcel triggers the recapture tax imposed by NRS 361.4725.

The recapture tax is triggered when, during a three year period, the taxable value of a parcel declines by 15% or more followed by an increase in value of 15% or more.  If the valuation of a parcel fits this roller-coaster pattern the resulting recapture tax can come as a surprise.  The impact is illustrated by the following example which is based on the assessor’s valuation of an actual parcel.

In year 1 the parcel was assigned a taxable value of $1,234,800.  In year 2 the taxable value dropped to $840,351 – a decline 32%.   The tax in year 2 (based on an assessment rate of 35% and tax rate of 3%) would be $8,824.

In year 3 the value of the parcel increased to $1,430,800 – an increase of 70%.  Despite the increase in value the tax cap limits the tax assessment to an increase of no more than $706 – 8% of the tax paid in year 2.  However, the fluctuation in value would trigger the assessment of a recapture tax of $1,515 in year 3. 

In this example the property owner would be assessed the 8% increase allowed by the tax cap and the 17% increase attributable to the recapture tax (although collection of the recapture tax would be spread over 3 years). 

Property owners appreciate the predictability provided by the tax cap in a rising real estate market but are often unaware that a recapture tax might be assessed.  No notice of the pending assessment is given; it just shows up on the tax bill.  Consequently, for many the assessment comes as an unwelcome surprise.

The tax bills for tax year 2022-23 will be issued in July.  Many of those bills are likely to include the assessment of a recapture tax because, following the outbreak of the coronavirus and the closure of businesses, the assessor assigned reduced values to many properties for tax year 2021-22.  Then, after businesses reopened and the incidence of infection waned, the assessor increased the values for tax year 2022-23.  This valuation pattern is likely to trigger the assessment of recapture tax for some properties.

It is always important to critically review the tax treatment of your property, but this year there will be one added factor to consider – the recapture tax.  Our property tax attorneys know the critical legal and valuation factors that affect the tax treatment of property in Nevada and are prepared to assist property owners in evaluating and, when appropriate, challenging that tax treatment.


Paul D. Bancroft
McDonald Carano
American Property Tax Counsel (APTC)

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Jan
01

New Hampshire Property Tax Updates

Updated december 2022

New Hampshire property tax bills have been issued

Most communities in New Hampshire have sent out their 2022 property tax bills. These tax bills have an assessing date of April 1, 2022. The property tax assessment of taxable real estate should be the fee simple market value of the property as of April 1, 2022, multiplied by the jurisdiction's median assessment ratio. If your property is assessed in excess of that amount, you may have grounds for a tax appeal. In general, abatement applications must be filed with the local assessors by March 1, 2023. If you are aggrieved by the action or inaction of the local assessors, you may file a petition with the State Board of Tax and Land Appeals or the Superior Court in the County where the property is located. The deadline for filing the petitions is generally September 1, 2023. There you will be afforded a full hearing on the merits where the rules of evidence will apply.

David G. Saliba
Saliba & Saliba
American Property Tax Counsel (APTC)

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Jan
01

Ohio Property Tax Updates

UPDATED march 2025

Ohio Revised Code 5713.031 and the Valuation of Federally Subsidized Residential Rental Property

ORC 5713.031 has changed the way many affordable housing properties are valued in Ohio.  While the Code became effective October 3, 2023, Ohio taxing authorities and practitioners have been waiting for the associated administrative rule to be finalized to provide clarity for its application.  That administrative rule is expected in the coming months.

ORC 5715.01(A)(4) outlines the uniform rule for determining the value of federally subsidized residential rental property and includes a formula for doing so.  The formula is based on the income approach to value and requires property owner action.  To seek valuation under the new process, a property owner must submit audited income and expense statements (up to three years) which include an allowance for vacancy and credit loss along with contributions to replacement reserves. 

The formula itself presumes an allowance of 4% for vacancy loss and replacement reserves of 5%, although presumptions of both can be rebutted and percentages can be exceeded with evidence from the taxpayer.  The respective 4% and 5% set the floor.  5715.01 also prescribes a minimum valuation equal to the greater of $5,000 multiplied by the number of property’s units, or 150% of the property’s unimproved land value.

The Code and methodology apply to housing projects restricted under Section 42 of the Internal Revenue Code, properties that receive assistance under Section 202 of the Housing Act of 1959, properties that receive assistance under Section 811 of the Cranston-Gonzales National Affordable Housing Act, Section 8 project-based assistance properties, and properties receiving assistance under Section’s 515, 521, and 538 of the Housing Act of 1949.

It is not mandatory that properties be valued using the formula.  Taxpayers must seek review of their financial information and submit it to their county auditor/fiscal officer/appraisal department by March 1 of the year before the property is put into service and after the commencement of the property’s operations, and every third year when there is a county reappraisal or update.

While property owners have been able to use the formula since its effective date, the absence of the associated administrative code has led to some uncertainty for tax practitioners in the State.  While we’ve seen assessments reduced based on submissions, disclosure of how reductions are being calculated remains a relative mystery.

Who is performing the review of the financial information?  Is it the auditor, the appraisal department, or some other body?  Is there an internal audit of the review?  Can the decision be challenged/appealed and if so, is that in the form of a complaint and legal proceeding through the board of revision?  If a property is subject to a reduction through the formula and also a board of revision value change, which one takes precedence?

Our firm and tax practitioners across the state anxiously await the publishing of the administrative code to help answer these, and many other questions.  Updates will follow.


Kristopher Nicoloff
Siegel Jennings Co., L.P.A.
American Property Tax Counsel (APTC)

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Jan
01

Oklahoma Property Tax Updates

UPDATED september 2024

Paying Taxes Under Protest and Potential Pitfalls

Once a taxpayer files a petition in district court or complaint in the court of tax review, it is imperative that the taxpayer still pays the taxes under protest by December 31st.  Failure to meet this deadline, or to pay taxes under protest, could result in dismissal of the taxpayer’s appeal. Make sure to check with your mortgage provider that they are not remitting payment of your property taxes without filing the required paperwork. If the taxes are paid without the required payment under protest paperwork, the taxpayer's appeal risks dismissal.

Kyle L. Ashpole
Elias, Books, Brown & Nelson, P.C.
American Property Tax Counsel (APTC)

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Jan
01

Oregon Property Tax Updates

UPDATED september 2023

Oregon Taxation of Delta Airlines Intangible Property Unconstitutional

In Oregon, centrally assessed properties have historically been subject to assessment of their intangible property. While locally assessed properties are statutorily exempt from taxation of intangible property, which includes a business’s work force, customer lists, patents, trademarks, trade secrets, goodwill, and contacts. 

In a significant decision, the Oregon Tax Court concluded that this statutory scheme, the taxation of intangible property listed for centrally assessed businesses, violated the Oregon Uniformity Clause and the federal Equal Protection Clause. The opinion was specific to Delta Airlines, because the court found no genuine differences between Delta’s (taxable) use of intangible property in its transportation business and the (exempt) use of intangible property in road transportation businesses or other businesses that rely on a network of property. How the court will later interpret “other businesses that rely on a network of property” is yet to be seen.

In this same decision, the court rejected the PacifiCorp’s regulated utility challenge because the court found genuine differences between PacifiCorp’s (taxable) use of intangible property in its business as a regulated public utility and (exempt) uses of intangible property in non-regulated businesses. Additionally, the court concluded the legislature could have determined that taxing the value of intangible property of a utility compliments the regulatory scheme by redistributing for public purposes some value that accrues through regulated operation that would otherwise be inure to investor-owners. 

As of the date of this writing, the Department of Revenue had not appealed this decision.

Delta Air Lines, Inc. v. Dep't of Revenue, No. TC 5409, 2023 WL 5425246 (Or. T.C. Aug. 23, 2023).


Cynthia M. Fraser
Foster Garvey PC
American Property Tax Counsel (APTC)

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Jan
01

Pennsylvania Property Tax Updates

UPDATED March 2025

Pennsylvania Legislator Proposes Cyclical Reassessment System

In January 2025, Pennsylvania State Senator Wayne Fontana announced that he plans to introduce legislation to move Pennsylvania to a cyclical reassessment system, as is the system in nearly every other state.

This is good news for taxpayers and other stakeholders. Pennsylvania is the only state in the United States to have a “base year” system under which counties can choose to stay in their “base year” (last year of the countywide reassessment) indefinitely. The State of Delaware - the only other state which had a base year system – in a decision by its highest court -- declared in May 2020 that a base year system of assessment is unconstitutional.

Due to Pennsylvania’s base year system, it is not uncommon for counties to fail to reassess for decades or more. The Pennsylvania County with the oldest reassessment year is Franklin County (south central Pennsylvania) which last reassessed in 1961. Pennsylvania is also one of a handful of states that allows government bodies to file increase assessment appeals (labeled “illegal spot appeals” in most states).  These two factors taken together – a county’s failure to reassess coupled with a school district’s right to “cherry pick” some taxpayers for increase appeals – leads to, as a practical matter, a disparate tax experience (especially for commercial taxpayers who tend to be the targets of school increase appeals) and a complete lack of uniformity in taxation, contrary to Pennsylvania ‘s Constitution.

APTC Western Pennsylvania Representative Sharon F. DiPaolo, Esquire, CRE, was invited to testify at Senator Fontana’s July 2024 hearing on the need for cyclical reassessment in Pennsylvania.  Ms. DiPaolo’s testimony called for cyclical reassessment to address the best practices of tax policy, namely, fundamental fairness, transparency, and consistency. As of this writing, the proposed legislation is in the process of being drafted. Siegel Jennings will advise of developments as they occur.

In the meantime, to discuss the specifics of this proposed legislation or your property tax needs in Pennsylvania, please reach out to:

Sharon F. DiPaolo, EsquireSiegel Jennings, Co., L.P.A.
American Property Tax Counsel (APTC)

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Jan
01

Rhode Island Property Tax Updates

Updated December 2022

File an account to protect your right of appeal

Now is the time for Rhode Island taxpayers to preserve their right of appeal for Tax Year 2023 by filing an account with the local assessor. In most jurisdictions the Tax Year 2023 tax bill will be sent out during the summer of 2023. The Tax Year 2023 tax bill has a valuation or assessing date of December 31, 2022. In most cases the filing of a valid account by January 31, 2023, is a prerequisite to a valid appeal. The account must describe the property, claim a value of the property, and be signed under oath and notarized. Occasionally the assessors do not send out account forms or the form may omit a section on real estate. It is incumbent upon the taxpayer to seek out a form and add a section for real estate if needed and properly complete and file it. It is acceptable for a taxpayer to construct his own account form, but it must include all required information and be signed under oath, notarized, and filed timely.

David G. Saliba
Saliba & Saliba
American Property Tax Counsel (APTC)

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Jan
01

Tennessee Property Tax Updates

UPDATED March 2025

Major Tennessee Reappraisals in 2025

Counties in Tennessee are required by statute to have 4, 5 or 6-year reappraisal cycles, depending on various factors, such as population.  Many of the largest counties are on 4-year cycles with a reappraisal coming up in 2025, including Davidson (Nashville), Shelby (Memphis), Hamilton (Chattanooga), and Williamson (Franklin).  The last reappraisal for these counties was in 2021, based primarily on data from 2019 and 2020.  These counties will reappraise again in 2025 based primarily on data from 2023 and 2024.  Taxpayers should be prepared for “sticker shock” when values come out, especially in fast-growing markets like Nashville.  Appeal deadlines vary by county.  Taxpayers should get with their property tax representatives as soon as they receive their value notices. 


Andy RainesEvans Petree PC
American Property Tax Counsel (APTC)

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Jan
01

Texas Property Tax Updates

Updated september 2024

Texas 1st Court of Appeals Provides an Important Reminder — the Filing Deadlines are Unforgiving

In Texas, fall is for football and escalating property tax protests. There are three different forums to escalate a Texas property tax protest that did not fall in your favor: (1) district court; (2) binding arbitration; and (3) State Office of Administrative Hearings. Each of these have unforgivably time sensitive deadlines and is highlighted by a recent case out of Texas’s 1st Court of Appeals.

In Harris Central Appraisal District v. Zheng, the property owner’s protest was denied and he decided to escalate by filing a lawsuit in district court. Section 42.21(a) of the Texas Property Tax Code establishes the time limit for this — 60 days after receiving the notice of the protest denial (known locally in Texas as a “board order”). Here, the property owner received the board order on September 5, 2020, making the lawsuit filing deadline November 4, 2020. But the property owner did not file until November 12, 2020. This is late and the district court dismissed his lawsuit.

To avoid the dismissal, the property owner attempted to argue that the intent of his pleadings must be considered in determining whether he complied with the 60-day deadline. Specifically, he intended to file the lawsuit timely but couldn’t because of extraordinary circumstances (Covid-19 and suffering a flesh wound on his left thumb). The 1st Court rejected this and recognized it as an acknowledgement that the property owner failed to file the lawsuit by the 60-day deadline and upheld the dismissal.

The takeaway from this quarterly blast is do not wait; file early if anything! The deadlines for escalating a protest that does not fall in your favor is unforgiving if missed, even by a day. This is true regardless of extraordinary circumstances, such as a global pandemic or serious injury (as shown by the above case). So, be vigilant in computing, knowing, and tracking deadlines.

To review the Opinion from Harris Cent. Appraisal Dist. v. Zheng, click the following link (or copy and paste): https://search.txcourts.gov/SearchMedia.aspx?MediaVersionID=82de247b-32b6-4bac-bc35-d051520e00cc&coa=coa01&DT=Opinion&MediaID=4bc8c61b-83a4-4d5e-abb5-61ac4a60328e.

Lee D. Winston
Michel Gray & Rogers LLP
American Property Tax Counsel (APTC)

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Jan
01

Washington DC. Property Tax Updates

updated june 2022

Proposed Changes to Assessment Appeal Process

In the District of Columbia, the assessment appeal calendar was designed for taxpayers to complete the two-level administrative appeal process prior to the payment of their property taxes. As a result, taxpayers often pay lower property taxes in the first instance as a result of successful administrative appeals, instead of paying higher taxes and then challenging the assessment through an administrative appeal.

The Office of Tax & Revenue (“OTR”) in the District of Columbia has recently proposed significant changes to the administrative appeal calendar, which is governed by the D.C. Code. Although proposed assessments are currently issued by March 1st each year, under OTR’s proposal, new assessments would be issued later in the calendar year. OTR’s justification for the change is that this would purportedly allow the assessors time to review the property’s most recent financial data that is reported annually through the Income & Expense report filing prior to the issuance of the assessment.

OTR's proposal suffers from serious flaws that would weaken the current protections provided to taxpayers. First, issuing assessments later in the year would necessarily push back or truncate the administrative appeal process. This would either result in a compressed administrative appeal calendar that does not provide the opportunity for sufficient review of taxpayers’ claims, or it would place taxpayers in the unenviable position of paying property taxes prior to the issuance of a decision on their administrative appeal. Second, diminishing the effectiveness of the administrative appeal structure that is currently in place would lead to additional appeals filed in D.C. Superior Court and burden the court system with appeals. Third, OTR alleges that its proposal would result in more “accurate” assessments. In our experience, however, more “accurate” assessments from OTR mean an unjustified increase in taxpayers’’ liability.  

In sum, the D.C. Code’s administrative appeal process was carefully crafted to provide a robust administrative appeal process for taxpayers, and there is no legitimate justification for tinkering with the current appeal calendar.


Wilkes Artis, Chtd.
American Property Tax Counsel (APTC)

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Jan
01

Wisconsin Property Tax Updates

Updated March 2025

Wisconsin Tax Appeals Commission Rejects State’s Attempt To Divest It Of Jurisdiction Over Large Tax Appeals

In a decision issued on March 11, 2025, the Wisconsin Tax Appeals Commission rejected an attempt by the Wisconsin Department of Revenue to divest it of subject matter jurisdiction over a large group of manufacturing assessment appeals involving millions of dollars in value.

The jurisdictional statute (Wis. Stat. 70.995(8)(c)1) states that objections to manufacturing assessments must be made “on a form prescribed by the department of revenue that specifies that the objector shall set forth the reasons for the objection … and the basis for” the objector’s opinion of value. The appeal form the Department of Revenue created under this statute includes a section for the objector to provide these two pieces of information. That section contains two adjacent boxes, one designated for the reason for the taxpayer’s objection and the other for the basis of the taxpayer’s opinion of value.

In the appeals in question, the taxpayers’ agent had placed text encompassing both pieces of information in the first box and left the second box blank. The State argued that leaving the second box blank per se divested the Commission of subject matter jurisdiction irrespective of whether all the required information was in the other box or elsewhere on the form.

The Tax Appeals Commission firmly rejected the State’s position, holding that as long as a taxpayer provides all the information required by the statute on the Department’s form the taxpayer has satisfied the jurisdictional requirement, whether or not the taxpayer has placed text in every box. The Commission’s decision was unusually harsh, finding one of the Department of Revenue’s arguments to be “frankly ridiculous,” and admonishing the Department to “restrain itself from making such frivolous and overreaching arguments” in future cases.

The case is Badger Mining Corporation and Smart Sand, Inc v. Wisconsin Department of Revenue.

Bryan J. Cecil
Hansen Reynolds LLC
American Property Tax Counsel (APTC)

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American Property Tax Counsel

Recent Published Property Tax Articles

When Property Tax Rates Undermine Asset Value

Rate increases to offset a shrinking property tax base will further erode commercial real estate values.

Across the country, local governments are struggling to maintain revenue amid widespread property value declines, as a result they are resorting to tax rate increases. This funding challenge increases the burden on owners of commercial...

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Pennsylvania Court Reaffirms Fair Property Taxation Protection

A tax case in Allegheny County also spurs a judge to limit government's ability to initiate reassessments of individual properties.

Pennsylvania taxpayers recently scored an important victory when the Allegheny County Court of Common Pleas reasserted taxpayers' right to protection against property overassessment, while limiting taxing authorities' ability to proactively raise...

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Dual Appraisal Methods Improve Opportunities to Get Fair Taxation for Seniors Housing Properties

The seniors housing sector can't seem to catch a break. Owners grappling with staffing shortages and other operational hardships lingering from the pandemic are facing new challenges related to debt and spiraling costs. High interest rates and loan maturations loom over the industry, with $19 billion in loans coming due...

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