HomeMy WebLinkAboutE&R 2006-05-22
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BOOK 1
PAGE 362
NEW HANOVER COUNTY BOARD OF
EQUALIZATION AND REVIEW, MAY 22, 2006
ASSEMBLY
The New Hanover County Board of Equalization and Review met on Monday, May 22, 2006, at 9:00
a.m. in the Assembly Room of the New Hanover County Courthouse, 24 North Third Street, Wilmington,
North Carolina. The purpose ofthe meeting was to hear appeals filed by property owners regarding their tax
value assessments.
Members present were: Chairman Robert G. Greer; Vice-Chairman William A. Caster; Commissioner
William A. Kopp, Jr.; Commissioner Nancy H. Pritchett; Tax Administrator Robert C. Glasgow; Assistant Tax
Appraisal Supervisor/Revaluation Coordinator Roger Kelley; Assistant County Attorney Holt Moore; and
Deputy Clerk to the Board Teresa P. Elmore.
Commissioner Ted Davis, Jr. was absent.
Chairman Greer called the meeting to order and welcomed everyone present. He informed the
appellants that the Board would make decisions following the hearings and the Tax Administrator would notify
each of them by mail of the Board's decision.
TAX APPEAL PRESENT A TIONS
TAX APPEAL: SPIRO J. MACRIS, 914 S. LUMINA AVENUE, WRIGHTSVILLE BEACH, NC;
TAX MAP NUMBER R06806-004-004-000
Tax Administrator Glasgow reported that the subject property consists of a single-family dwelling
located at 914 S. Lumina Avenue, Wrightsville Beach. The dwelling, built in 1965, is of brick and frame
construction. The assessed value is $471,766.
Appellant's Argument: The appellant believes that the value should not change as there has been no new
construction to the property since he purchased it in the late 1970's. The appellant believes that the Tax
Department received information from a bank appraisal on his property, which prompted an increase in the tax
value.
Assessment Support: The reason for the value change was a discovery of a portion of the dwelling which
was not properly identified and valued during the initial software conversion in 1991. A Base Over Garage
(BOG) in the old OASIS software required the area of both the garage and room over the garage to be entered
into the database twice. During the recent conversion of the tax data from the OASIS software to the new
IAS4 software, more than 100 similar situations were identified and corrected. Dr. Macris was notified of an
$11,700 increase in the 2006 evaluation.
The Tax Department had no knowledge of the appellant's appraisal by the bank. It would have been a
violation of the Uniform Standards of Professional Appraisal Practice if the County had used the appraisal
without the appellant's permission. Secondly, the tax value is based on the 1999 Schedule of Values and
would be in conflict with a new appraisal. North Carolina General Statutes require the correction of all
identified errors regardless of when they are identified. The correction applies for tax year 2006 only, meaning
the appellant did not pay taxes on this portion of his property for 15 years. General Statutes allow Counties to
go back 5 years to correct a clerical error.
Conclusion and Recommendations: The taxpayer did not provide evidence to support his claim that the
County used the bank's appraisal to increase the assessed value. Therefore, the increase in value of$11,700
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NEW HANOVER COUNTY BOARD OF
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BOOK 1
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for tax year 2006 is correct and appropriate in accordance with North Carolina General Statutes.
Dr. Spiro Macris, property owner of 914 S. Lumina Avenue, presented his appeal saying that no
additions or modifications have been made to his home and the garage has always been a part of the house. He
received a valuation change notice on March 6, 2006, just after receiving a bank appraisal on February 23,
2006. He questioned the Tax Department about the circumstances and he wanted to know more about the new
appraisal software that changed the value of his home. He did not claim the value exceeded the 1999 value,
but questioned why an evaluation took place prior to the revaluation scheduled for next year. He felt that the
Tax Department was pressuring him against appealing the value by saying they could apply the correction for
the past five years.
Mr. Glasgow reported that the County purchased the new tax appraisal software from Tyler
Technologies/CL T Division. When comparing the new software program with the old OASIS system using
the 1999 Schedule of V alues, they found the area of the garage was not assessed. He assured the Board that it
was simply a clerical error made during the conversion of 1989 and 1991 which carried forward until the new
software program found the error.
Mr. Kelley reported that the new software also found errors in value for 81 porches. In order to make
future discoveries or releases, values calculated by the new software must match the values of the old program.
Some homeowners were notified in November of the correction, but most were notified in February.
Adjustments were between $10,000 and $20,000 per home.
Commissioner Kopp confirmed that the County made a mistake and the adjustment was not from a
discovery of a garage or any addition.
Mr. Glasgow pointed out that 11,000 homes with base over garages were done correctly. The square
footage was captured correctly, but a coding error was found. No value was entered for the garage. It was a
coincidence that the mailing was sent out at the same time that Dr. Macris received his bank appraisal.
In further discussion, Chairman Greer said that the County determines the value of a structure based on
the square footage. He believed that the value of the house should not change since no change had occurred on
the structure.
Dr. Macris expressed appreciation for the Board's consideration.
Motion: In deliberations after the hearings, Commissioner Pritchett MOVED, SECONDED by Vice-
Chairman Caster, to uphold the assessed value of$47l,766, as recommended by the Tax Administrator.
Chairman Greer believed that an increase in the assessment was not justified. He felt that the value
should be reduced because the value ofthe garage was included in the living space.
Vote: Upon vote, the MOTION CARRIED 2 TO 2. Chairman Greer and Commissioner Kopp voted in
opposition.
In further discussion, Mr. Glasgow reiterated that the homeowner must prove the adjusted value is
incorrect. He reported that if the Board does not uphold the value, the Tax Department will need to waive the
adjustments for the other 180 homeowners with similar errors.
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NEW HANOVER COUNTY BOARD OF
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Chairman Greer disagreed with Mr. Glasgow saying that the circumstances may not be the same for
the other homeowners.
Mr. Kelley explained that the structure has 2,000 square feet ofliving space and is valued at $75 per
foot for the heated area. The property should have received a value for the garage area, but it did not.
Commissioner Kopp expressed concern that the homeowner believed that the County increased the
value because of the bank appraisal. He felt that too many questions existed on the reasons for the
adjustments. However, Commissioner Kopp said he would trust that the Tax Department handled the
assessments properly and he would change his vote.
Mr. Glasgow assured the Board of his integrity and veracity to do his job and he would not infringe
upon property owners' rights to question the validity of their valuation.
Change of Vote: After receiving the assurance from the Tax Administrator, Commissioner Kopp changed his
vote to affirm the assessment of $471,766. The MOTION CARRIED 3 TO 1. Chairman Greer voted in
opposition.
TAX APPEAL: RUTH E. YARBOROUGH AND LAURA PARKS, 169 SPRING CREEK LANE,
WILMINGTON, NC; TAX MAP NUMBER R03718-007-025-000
Tax Administrator Glasgow reported that the subject property consists of a 16,553 square foot vacant
lot located in the Spring Creek! Argean neighborhood of Middle Sound. The zoning for this neighborhood is
R-20. This parcel was subdivided by the developer/owner and later sold to Ruth E. Yarborough. The property
owner beyond the subject parcel accesses his property on the north side of the vacant lot. However, no
easement or right-of-way is recorded for his use. The assessed value is $38,000.
Appellant's Argument: The appellant believes that the assigned tax value is not representative ofthe 2006
fair market value since the subject parcel was denied a variance by the New Hanover County Board of
Adjustment on June 24, 1997. Laura N. Parks presented a letter from Mr. Bruce W. Deschamps, a certified
real estate appraiser, stating the land has no value. Therefore, Ms. Parks has requested the assigned land value
be changed to reflect no value.
Assessment Support: After reviewing Ms. Parks appeal, it was agreed that the subject parcel was
unbuildable under New Hanover County zoning requirements and minutes of the Zoning Board of Adjustment.
The Tax Department does not agree with Mr. Deschamps that the parcel does not have any value. Every
parcel in New Hanover County has some value. The subject parcel has value for several reasons. The owner
directly behind the subject parcel was the developer ofthis area and he must access his residence through the
northern side of the subject property. Although the subject property is unbuildable under current zoning
regulations, it would appear that the property owner directly behind the subject property would want to
purchase the property since there is no record of an easement on the subject property. Perhaps the property
could be used as a small park or green space.
Conclusion and Recommendation: The Tax Department agreed that the assigned tax value of$38,000 is
excessive for an unbuildable parcel in this neighborhood, and has agreed to reduce the value to $19,000. Ms.
Parks does not accept that value. It is recommended that the tax value for 2006 be reduced to $19,000 as an
unbuildable lot.
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NEW HANOVER COUNTY BOARD OF
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BOOK 1
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Laura N. Parks, daughter of Ruth E. Yarborough the property owner, stated that she lives at 101
Spring Creek Lane and she has power of attorney for Ms. Yarborough. Ms. Yarborough purchased four lots in
the early 1980s and built and sold homes for 3 of the lots. She received well and septic permits for the
remaining lot, but was unable to get a building permit. A deficiency in the lot size of 8/1 00 of an acre went
undetected when the subdivision plat was approved by the Planning Department. She had requested a variance
from the Zoning Board of Adjustment for the deficiency, but was denied because the neighbors who attended
the meeting objected. She believed she did not receive a fair hearing because the chairman at that time, Pete
Devita, had a conflict of interest. She recently learned that Mr. Devita's brother lives and owns property at 114
Spring Creek Lane. Even though a structure would not conflict with any set back requirements of the Zoning
Ordinance, no deal could be negotiated with the neighbors for a variance.
Assistant County Attorney Moore advised that the primary concern before the Board of Equalization
and Review was the decision made by the Board of Adjustment. Unless a variance is granted, the lot cannot be
built upon.
Ms. Parks said she is unable to get health care and housing assistance for her mother because her
mother owns the lot. Furthermore, she is unable to sell or borrow money on the lot because of the unrecorded
easement and lot size issues. She requested the Board to change the assessment ofthe lot to no value. If the
status of the lot changes, she realized that she would be required to pay taxes for the property.
Mr. Glasgow responded that a value change can be made, but they are unable to go back and make
changes for past years. He reiterated that the property has some value, whether an adjacent property owner, the
County, or the community purchases it for green space or a park area.
In deliberations after the hearings, Commissioner Pritchett agreed with Staff that all property in the
County should have value particularly on Middle Sound.
In discussion of the 1997 decision made by the Board of Adjustment, Assistant County Attorney
Moore advised that Ms. Parks should make a formal appeal to the Zoning Enforcement staff if she has a
contention about the decision. Staff would forward her appeal to the Legal Department for advisement. The
Board of Adjustment could reconsider the request.
Motion: Chairman Greer MOVED, SECONDED by Commissioner Pritchett, to reduce the assessed value to
$19,000, as recommended by the Tax Administrator. Upon vote, the MOTION CARRIED 4 TO O.
TAX APPEAL: FBC HOLDINGS, LLC, 20 NORTH FOURTH STREET, NC; TAX MAP NUMBER
R04817-030-001-000
Tax Administrator Glasgow reported that the Tax Administrator initially approved the Application for
Property Tax Exemption submitted by Attorney W. Berry Trice on behalf ofFBC Holdings LLC, the owner of
the former New Hanover County Law Enforcement Center. The initial approval of tax exemption was based
on the property being used on January 1,2006 for charitable purposes by First Baptist Church. An internal
review by the Tax Department, followed by a review through the Legal Department, and validation of those
findings by the Property Tax Division of the Department of Revenue, agreed that, since FBC Holdings, LLC
was not the primary user of the property, such an arrangement would cause the organization not to qualify for
tax exemption.
Portions of the property are leased to New Hanover County for much less than the standard square foot
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NEW HANOVER COUNTY BOARD OF
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BOOK 1
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rents charged throughout the area. A qualifying charitable organization is permitted to lease or rent space to
other religious, charitable, educational, literary, cultural or scientific organizations so long as the amount
charged is nominal and no profit is realized from the arrangement. The question of leasing to a governmental
organization would appear to not be a disqualifying condition as long as the funds received are nominal. Other
portions of the building are used to store equipment that was left on site when the building was vacated by the
County. Much of this equipment, such as beds, tables, chairs, kitchen and food preparation equipment etc.,
will be used by those organizations that will eventually lease office space in the building. Storage of
equipment for charitable organization(s) is considered appropriate and does qualify a property for tax
exemption. The Jo Ann Carter Harrelson Center, Inc. has a lease agreement with FBC Holdings, LLC for a
portion of the building. The Center is the primary administrative coordinator for use ofthe building by other
charitable organizations. The assessed value is $10,428,042.
Appellant's Argument: The appellant believes that portions if not all ofthe property should qualify for tax
exemption.
Administrative Space: For most of2006 all of the administrative space in the building will continue to be used
by New Hanover County for its 911 Center, Emergency Operations Center and the Criminal Investigation
Division of the Sheriffs Department. Once the County vacates the building, which is expected to occur the
later part of 2006, the administrative space will be occupied by other charitable or nonprofit entities that
provide services to low income or impoverished citizens. The intention is to only charge enough rent to cover
the costs of operating and maintaining the administrative space.
Cell Tower: The owner intends to build housing in the cell tower space for individuals with low or moderate
income. The owner is in the process of making application for low income housing tax credits to assist with
the costs of rehabilitating the cell tower area to accommodate such use.
Parking Spaces: On weekends and after work hours during the week the parking spaces are used by First
Baptist Church. During working hours, New Hanover County continues to use, free of rent, 26 parking spaces
while they occupy the building. The remaining spaces are used by or rented to third parties during working
hours. The owner's intent is to charge only enough rent to cover the costs of operating and maintaining the
parking spaces.
Assessment Support: G.S. 105-278.6(8)( e) is understood to have been written and adopted by the General
Assembly as a result of a request from Habitat for Humanity. The NCDOR has stated a specific criterion was
written into the statute to insure that qualifying organizations had five years to construct housing for low-to-
moderate income families or individuals, and the tax would be deferred for that five-year period. Ifhousing
was not built within that five-year period, taxes and interest would become due and payable. Habitat for
Humanity is not in the business of providing long-term housing for low-to-moderate income families and
individuals, rather they construct housing and transfer ownership to qualifying low-to-moderate income
families or individuals. It is both the Department of Revenue and the Tax Department's opinion the statute was
written with the purpose of exempting qualifying organizations that build and provide long-term housing for
low-to-moderate income families and individuals.
Secondly, only a very small portion ofthe building was used by the appellant on January 1,2006 for
any ofthe charitable purposes proposed. Granted portions of the building were leased to a government entity,
but the lease agreement between FBC Holdings, LLC and the County as a local government should not be
considered for exemption based on his interpretation of the general statutes.
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Conclusions and Recommendations: If the building was not being used for its intended purposes on January
1, 2006, FBC Holdings, LLC would not qualify for tax exemption. If it is determined that FBC Holdings, LLC
was using the building for tax exempt purposes on January 1, 2006, the storage area for the furniture and
equipment would also qualify for tax exemption. The portion which is leased to the County would be taxable.
It is the Tax Department's recommendation that since the owner has formed a limited liability
corporation and sublet the entire property to the Jo Ann Carter Harrelson Center, FBC Holdings, LLC should
not qualify for tax exemption.
W. Berry Trice, Attorney with Murchison, Taylor & Gibson, PLLC, presented the appeal for tax
exemption for FBC Holdings, LLC, the holding entity who purchased the property in October 2005. FBC
Holdings, LLC has leased the property to a new non-profit organization, the Jo Ann Carter Harrelson Center,
Inc. for $1.00. The Harrelson Center was created to operate the building.
Mr. Trice said the appeal is based on IRS Announcement 99-1 02 which allows a charity organization
to hold property for environmental reasons or other liability issues in a holding entity. For tax purposes, the
entity is treated as a division ofthe church and shares the exemption ofthe parent. Secondly, the cell tower of
the complex is to be refurbished for housing of low-to-moderate income families and they plan to apply for
low-income housing tax credits. If tax credits are not awarded, they will raise money for the refurbishing. The
law allows tax exemption of real property owned by a non-profit organization for the purpose of providing
housing for low-to-moderate income families. They will need to construct the housing within 5 years to keep
the tax exempt status. If the housing is not constructed, the County can collect back taxes. IfFBC receives tax
credits, the property will be transferred to investors, who will use the tax credits. The property would be
transferred back to the non-profit entity after 15 years.
Mr. Trice said he had discussed the issue with Lee Harris of the N. C. Department of Revenue. He
came away believing that the statute would apply to other entities besides Habitat for Humanity when property
is transferred for low income housing. He contended that the County could grant a tax exemption as it would
for Habitat for Humanity.
Mr. Trice reported on the current uses of the facility that he believed qualify all of the property for tax
exemption. He believed that since both charity-owned property and government-owned property are tax
exempt, the areas rented to the County should qualify for tax exemption. He requested the Board to grant the
tax exemption for the entire property.
In discussion of the jail space, Mr. Trice spoke of plans to remove the top two floors of the jail cells for
housing units. Currently, the Harrelson Center is interviewing charities who will provide services for the poor
in the downtown area. They hope to provide a free or low-cost prescription pharmacy and a clinic. A part-time
executive director and other staff members have been hired, but a good part ofthe work has been done by the
volunteers of the church.
Mr. Glasgow responded that GS 105-286 was specifically written with the Habitat for Humanity in
mind and it did not include any other non-profits. He felt obligated to inform the Board that some of the
property may not qualify for tax exemption at this time. The law allows charities that rent to other charitable
organizations the tax exempt status, but it does not address charitable organizations renting property to
governments.
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NEW HANOVER COUNTY BOARD OF
EQUALIZATION AND REVIEW, MAY 22, 2006
BOOK 1
PAGE 368
During the deliberations after the hearings, Mr. Glasgow reported that the tax value of the property
was not included in the tax base budget analysis.
Motion: Vice-Chairman Caster MOVED, SECONDED by Chairman Greer, to grant a tax exemption from ad
valorem taxation beginning in 2006 for the property currently owned by FBC Holdings, LLC. Upon vote, the
MOTION CARRIED 3 TO 1. Commissioner Pritchett voted in opposition.
TAX APPEAL: CANEBREAK APARTMENTS L TD PARTNER, 4805 GREENWAY A VENUE,
WILMINGTON, NC, TAX MAP NUMBER R04919-008-012-000
Tax Administrator Glasgow reported that Frank Slaughter, National Tax Resource Group, filed an
appeal for the Canebreak Apartments. The complex consists of an office/community building, 5 apartment
buildings with 4 units, and 2 buildings with 6 units. The zoning for the neighborhood is MF-L. It is located in
a community of single- family houses and apartments, bordered by commercial properties. The assessed value
is $1,696,032.
Appellant's Argument: The appellant believes that the value of the property should be based on the income
generated from actual rents. Residents must be age 55 or older to qualify for the apartments and rent payments
are based on the individuals' incomes. Based on actual rents and expenses, the appellant believes the value of
the property should be $1,100,000.
Assessment Support: Researching the local apartment rents in the area, it was determined that market rents
were considerably higher than the subject property. The appellant's rent information did not reflect the total
income from tax credits or loans with low interest rates. The North Carolina Supreme Court ruled that tax
credits and low interest rates must be factored into the income stream in order to arrive at a true market value.
Secondly, the building permits list the construction value at $2,716,023, which is twice the amount the
appellant listed the value. The Tax Department requested all documents supporting the appellant's argument
be provided by May 12,2006. Specifically, they needed to see the tax credits to appropriately calculate the
income stream. However, no additional information was submitted by the appellant.
Conclusion and Recommendations: The Tax Department recommends no change in value. In North Carolina
it is incumbent upon the appellant to show that the tax value is incorrect.
Frank Slaughter, National Tax Resource Group, was not present to give the appeal.
In discussion, Mr. Kelley explained that tax credits are used as an incentive for developers to provide
low-income housing. Although the construction cost was approximately $2.4 million, the assessed value is
based on the 1999 Schedule of Values. He recommended to uphold the value.
Motion: Vice-Chairman Caster MOVED, SECONDED by Commissioner Pritchett, to uphold the assessed
value of$1 ,696,032, as recommended by the Tax Administrator. Upon vote, the MOTION CARRIED 4 TO
O.
TAX APPEALS WITHDRAWN
Tax Administrator Robert Glasgow reported that the following appellants have either withdrawn their
appeals or have agreed to adjustments as negotiated with staff. He recommended that the Board affirm the
assessed values of the following:
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NEW HANOVER COUNTY BOARD OF
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Christ's Sanctified Holy Church /Jernigan, Samm
Johnson, Richard
McNeill, Samuel F.
Harrington, George W. & J oann
R03 614-00 1-0 19-000
R06700-002-052-000
R06200-004-0 16-000
R0541 1-001-002-000
R05411-00 1-003 -000
R06319-005-005-000
R08800-005-0 14-000
R08800-005-0 15-000
R08800-005-0 16-000
R051 12-010-018-000
Bremer, Emma
Food Lion, LLC
King, Charles B.
Motion: Commissioner Pritchett MOVED, SECONDED by Vice-Chairman Caster, to affirm the assessed
values of the appeals that were withdrawn or agreed upon. Upon vote the MOTION CARRIED 4 TO O.
ADJOURNMENT
There being no other business, Chairman Greer adjourned the 2006 Board of Equalization and Review
at 1 1 :25 a.m.
Respectfully submitted,
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Teresa P. Elmore
Deputy Clerk to the Board
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