As the Common Level Ratio (CLR) for properties in Allegheny County has been dramatically reduced over the past three years (from 86.2% in 2021 to 63.5% in 2022; and from 63.6% in 2023 to 54.5% in 2024), the number of real estate tax assessment appeals filed has increased.  More than 30,000 assessment appeals were filed in 2022 and 2023 in Allegheny County, and many of those appeals remain unresolved at the initial Board of Property Assessment Appeal and Review level.  The next level, the Board of Viewers, cannot yet even forecast how many appeals it will end up dealing with.

Every summer, the Pennsylvania State Tax Equalization Board (STEB) unveils the CLR for each county. These ratios directly relate to how real estate assessments will be calculated in a tax appeal process. In July 2023, STEB released the CLRs applicable from July 1, 2023 to June 30, 2024, and the current CLR of 54.5% indicates that owners of real estate in Allegheny County may be able to reduce their real estate assessments and corresponding real estate tax payments.

CLRs are to be set based upon actual sales data collected from each county. Its purpose is to adjust current fair market values as compared to the “base year” of the last countywide reassessment (which is 2012 for Allegheny County). Meaning, the current assessed value for a property in Allegheny County should reflect what the property “should have been worth in 2012” – not what that property is or should be worth today. If property values generally increase in a county and assessments are not similarly increased, the CLR will often decrease.

Counties do not automatically apply the CLR in computing real estate taxes. Instead, they employ their own predetermined assessment ratio (PAR), and many counties utilize a PAR of 100%. With the current CLR of 54.5% in Allegheny County, there is often a meaningful disparity between the PAR utilized by the County and the current CLR. It is incumbent upon the taxpayer to file an appeal to correct overassessments resulting from these types of discrepancies – often with the taxpayer arguing to apply the CLR instead of the PAR.

The formulas for calculating real estate tax payments for any particular property are as follows:

  • Property’s Fair Market Value multiplied by (CLR or PAR) = Assessed Value
  • Assessed Value multiplied by Millage of applicable taxing entity = Tax Payment

Every element of the formula is subject to change, and every element involves a mixture of objective, subjective and political determinations.  Offering predictions in this tax assessment environment has become increasingly difficult.  However, a decline in the CLR generally works to the benefit of property owners.

Before any appeal is filed, the property’s fair market value must be competently estimated to confirm that an appeal should be pursued.  This is particularly important for income-producing properties which require a detailed analysis of a property’s income and expense profile, which is often fluctuating from month-to-month. The 22.7% decline in CLR from 2021 to 2022 was so significant that assessment appeals remained cost-effective even if some increase in fair market value was likely. The CLR has declined another 9.1% from 2023 to 2024.  And, if the particular property’s fair market value has declined, savings will be even more significant.

As for the millages aspect of the equation, one might expect that the reduction in tax base due to lowered assessed values would create a need for millage increases.  Taxing entities have objected to the dramatic changes to CLR, arguing such reductions will meaningfully reduce the tax revenue they rely upon. However, neither Allegheny County, nor the City of Pittsburgh, nor the Pittsburgh School District have increased millages in their recently passed budgets for 2024. This may be a result of the lack of finality in the currently pending 2022 and 2023 appeals, combined with the increasing backlogs at all appeal levels.  But, if (or when) millage increases are necessary, and they almost certainly will be, a taxpayer who has not filed an assessment appeal to take advantage of a CLR decline may find themselves paying more for taxes as the assessed value of their property remained constant. Although any property owner may file an assessment appeal annually, the CLR will change annually. There is no assurance that 54.5% or anything close to that will last beyond this year.

For those who filed appeals for 2022 and 2023 that are fully concluded and final:  There may not be as much savings to obtain as in the past two years, as the CLR is 9.1% lower in 2024 vs. 2023.  However, fair market value determinations may suggest a further 2024 appeal.

For those who filed appeals for 2022 and 2023 that are not fully concluded and final:  You are deemed to have already appealed for 2024 because, by law, every taxable year such an appeal is pending will be addressed in a final disposition.

For those who have not yet filed any assessment appeal or need help with another:  Now is the time to compile the relevant fair market value information, together with a full income and expense profile for your property.  The deadline for filing an appeal is April 1, 2024.

Metz Lewis attorneys have been active in assessment appeals in Allegheny County for years. This includes reassessments of office buildings, retail projects, industrial facilities, and apartment complexes. In all cases, the focus is on the value to clients, cooperative and efficient use of independent expert appraisers, and capitalizing on the experience and skill of our attorneys to appropriately value the property to ensure accurate tax assessments.

If you have questions or would like additional information about real estate tax assessment appeals in Allegheny County, please contact Steven Petrikis (spetrikis@metzlewis.com) or Rachel Felton (rfelton@metzlewis.com).

This article should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only and you are urged to consult a lawyer concerning your own situation and legal questions.

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