A change in the filing deadline hasn’t led to a groundswell of 2025 property assessment appeals in Allegheny County. In fact, if anything, it has been just the opposite.
With Tuesday’s cutoff at hand, only 2,113 appeals had been filed for the 2025 tax year as of Monday.
Unless there’s a massive dump of last-minute appeals, the number would be far less than the 7,428 appeals filed for 2024; the 11,983 submitted for 2023; and the 19,683 filed for 2022, including 6,877 so-called second-chance appeals.
Mike Suley, an assessment board member and former county assessment director, was surprised by the lower number so far.
“I’ve never seen anything like this in 30 years,” he said, adding that the norm for appeals in any given year is 8,000 to 9,000.
Typically assessment appeal filings in Allegheny County have been a rite of spring, with the deadline usually March 31. But this year, the county moved it up six months to Oct. 1.
It did so in an effort to give taxpayers and taxing bodies like school districts and municipalities a better idea of what kind of tax bills and revenues they can expect next year.
The change also brings Allegheny County in line with other counties in the state, virtually all of which have spring or summer deadlines to file appeals for the coming year.
With the new deadline, the goal locally is to have all 2025 appeals decided by the time 2025 tax bills go out early next year.
In the past, the March 31 deadline meant that assessment changes made during appeal hearings in spring and summer were applied retroactively, making it difficult for property owners to estimate how much they would owe in taxes and for taxing bodies to calculate revenues.
Nonetheless, neither Mr. Suley nor others involved in the appeals process saw the deadline change as the main reason for the low number of assessment challenges so far.
They believe a more compelling factor is at work — the steep drop in the common level ratio, the number used in appeal hearings to calculate taxable value. It has dropped from 87.5% a few years ago to 54.5% this year. It will tumble again to 52.7% for the 2025 tax year.
The lower ratio is much more advantageous to property owners than to school districts and municipalities, which typically file appeals to raise assessments closer to the sales price to generate more revenue without increasing taxes.
While district and municipal officials have defended the practice as one of the few ways to raise revenue sans routine reassessments, critics have dubbed it as a “welcome neighbors” or “newcomers” tax.
But these days, with the lower ratio, even in situations where the fair market value of a property is raised significantly, those gains could be more than offset once the ratio is applied to determine taxable value, producing a loss for the taxing bodies.
As a result, they must determine whether an appeal is worth it given the circumstances, said Ira Weiss, solicitor for the Pittsburgh Public Schools and a number of other taxing bodies.
“You don’t want to win on the valuation question but have a net loss once the common level ratio is applied. That’s the classic example of a pyrrhic victory,” he said.
He added that “taxing bodies are determining that there’s not enough prospect of overall success after you apply the common level ratio to justify the appeal.”
That reluctance is borne out in a breakdown of the appeals filed so far. Of the 2,133 challenges, less than a third — 693 — have come from districts and municipalities. In some years, the Pittsburgh Public Schools alone has filed more than that.
In fact, a study by the Allegheny Institute for Public Policy found that of the 8,216 appeals submitted in 2020, 75% of them were triggered by the taxing bodies, with the vast majority of them generated by school districts.
Dominick Gambino, a former county assessment director who now works as a consultant for taxing bodies, also saw the common level ratio as the culprit.
“Since the CLR has been reduced 30 points in a very short time period due to the county miscalculation over who knows how many years, the return on investment is much lower,” he said.
Of the appeals so far, the vast majority — 1,407 — have been filed by property owners. But Mr. Suley believes that number could be higher if more taxpayers understood and trusted the math behind the common level ratio.
“Even if they do the math, they’re still skeptical about the math,” he said.
Another factor that could be at work in the lower number of appeals is that owners of many “substantive properties” have already filed assessment challenges the past few years as the ratio has plummeted, said Edward Hirshberg, an attorney who handles commercial, industrial, and some residential appeals.
That leaves fewer taxpayers looking to appeal. For example, this year, his office expects to file “dozens of appeals rather than the hundreds we filed in 2022-2023,” Mr. Hirshberg said.
Like Mr. Suley, he doesn’t believe the change in the deadline has had much to do with the lower number of appeals.
“Part of my job is to make sure clients know when the deadline is. We would have filed a comparable amount in March 2025,” he said.
If there’s any consolation for school districts and municipalities in the filings so far, it’s that only 249 commercial property owners are challenging their 2025 assessments. That’s down from 1,277 in 2024; 1,394 in 2023; and 1,986 in 2022.
Many of those appeals have resulted in substantial reductions in taxable value, particularly in Downtown, where assessments have tumbled by more than half a billion dollars in the past few years.
That has resulted in millions of dollars in refunds and revenue losses for the city, the Pittsburgh schools and the county. The district has estimated that it has doled out about $22 million in tax refunds over the past few years because of the changes.
In part because of the situation, the district has filed a lawsuit to force a countywide reassessment. It is still pending in Common Pleas Court.
The county is fighting the litigation, claiming that the district doesn’t have the right to file such a lawsuit and that it can offset any revenue shortfalls caused by assessment appeals simply by raising taxes.
First Published: October 1, 2024, 9:30 a.m.
Updated: October 1, 2024, 7:15 p.m.
