Our tax appeals specialist Nicole Amick delves into the complexities of property tax appeals in Allegheny County, focusing on the recent changes in filing deadlines and procedures.
In this episode we discuss the implications of these changes for Pittsburgh and Allegheny County area homeowners and potential buyers.
This is a must-listen for long time home owners or anyone contemplating buying a home, as we touch upon the importance of understanding the common level ratio and the potential impact of reassessments on property values.
As always you can contact Nicole directly at nicole@pghfirm.com to discuss the specific details of your property situation and how we can help you save money on taxes.
Speaker 1 (00:00.6)
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Speaker 1 (00:34.818)
Hi, this is Bill Rogel from the Pittsburgh law firm, Flaherty Farto joining me today. Noah Palfarta, managing partner of said law firm and the queen of tax appeals herself, partner in the law firm. This is Nicole Amick. And we're here today to just kind of update what's been going on in the constantly shifting and always existing world of property tax appeals in Allegheny County, PA. As the queen of tax appeals, Nicole, let me just jump right in. Look, you've been doing this for how long now?
more than 15 years.
And for the first 13 of those years, the deadlines every year for filing your appeals were basically unchanged, right? It was the same thing every year. Sometimes it fell on a weekend, but it shifted. Over these last two years, last year and now this year again, things are different. So for someone who has lived here for a while and has maybe even dealt with this before, even for us,
the timelines, the deadlines, the actual practical method of dealing with appeals when they're filed and so on has changed. Can you tell us what's going on this year? I'm filing an appeal, if I'm getting an appeal, what are the deadlines? What are the dates I need to know?
Yes, it has been changing like everything else with assessments. You never, never a dull moment. So what they have started doing now is we used to file appeals in the actual tax year. So for example, in 2024, the appeal deadline was March 31st, 2024. So you would file at the beginning of that actual year. What we have now shifted to is a system where we file appeals in advance of a year.
Speaker 2 (02:09.452)
So the deadline for 2025 appeals has already passed. It was October 1st, 2024. So we are now filing appeals in advance of that year. The deadline this year has changed again. So the deadline for 2026 appeals is September 1st, 2025. So if you want to challenge your appeal, your taxes for next year, you have to file an appeal this summer.
So definitely a different system than we've had before in Allegheny County, a lot of confusion about it. I've had a lot of property owners reaching out to me to file appeals for this year. Unfortunately, I have to tell them we've missed the window, but already trying to get clients in line for 2026 appeals.
So just to try to clarify a little bit here, up until two years ago, if you wanted to appeal your current year's taxes now, February, you would still be able to do that. That is no longer the case. If you want to appeal your 2025 property taxes, you can't do it, right? The deadline has passed.
Correct. So for example, I'll have people that are buying houses right now saying, I want to appeal my taxes and I have to tell them, great, we can appeal for next year, but the taxes that you're going to get for this year, we've already missed the window to do that. The reason that they've changed the deadline is they're trying to deal with all these tax deficits and changing of the tax base in advance of people actually paying the taxes. So this is what I think all the other counties in Pennsylvania do. We're kind of just shifting into being like those other counties, but basically
If I file an appeal this summer for 2026, I would conceivably have a hearing this fall, get my decision before I have paid any 2026 taxes. So the number would presumably be changed to reflect the accurate value before those tax bills are sent out, which will help with all the deficits that the tax bodies are dealing with now for past years. That's the idea anyway, if the system runs perfectly, which as we know, it typically does not.
Speaker 3 (04:06.7)
Nicole, I have a question. So when is the deadline again?
The deadline for 2026 appeals is September 1st, 2025.
So if I buy a property on September 2nd of this year for $500,000 and it's assessed at 2 million, when is the earliest I can appeal?
Technically, the earliest you would be able to appeal in that situation would be for 2027, the next year. There is a process for filing a late appeal, but that's kind of a convoluted process, but you would have already missed the actual appeal deadline for 2026.
Would pay on an unfair value, not only for three months in 2025, but all of 2026, 15 months of there's nothing I can do about it, regardless of the real value of the property.
Speaker 2 (04:55.448)
Correct. As I said, there is a late filing process, but just because you buy a property later, that does not give you a window to say, hey, I bought a property later. That doesn't matter because you're past the deadline and it is what it is.
Bill, what do you think of that?
Well, look, the theory here is that the sale doesn't change the actual value of the real estate. It's just evidence of the value of the real estate. So if your house is assessed at two million and the prior owner didn't think that they needed to file an appeal, well, you're out of luck then until now you've got your evidence. Now you're able to appeal for 2027. It's frustrating because you've been overpaying and the sooner you can get that looked at the better. But the theory here is nothing about the actual value of the real estate changed when you bought
It's worth the same amount tomorrow as it was yesterday.
So Nicole, following up on that, if I'm going to buy a property and try to close by the appeal deadline of September 1st, what advice can you give to potential buyers during, who are in the process of executing sales agreements? Is there anything they should know before they sign a sales agreement with regards to their property taxes?
Speaker 2 (06:04.482)
first thing I will say and I have helped people do this is if you are buying a property after the appeal deadline and you think the property is over assessed you can have the current owner file an appeal for you and you could then take over that appeal so you basically don't lose the opportunity to challenge the year that we are in. So that's number one. Number two you need to understand how the common level ratio works so you need to be able to look at what you're buying the property for
apply the ratio and you can then determine what an accurate or fair assessment value for your property would be. So for example, in 2025, the common level ratio is 52.7%. So if you have a property worth a million dollars, just to give us an even number, technically, if you bought that property for a million dollars, the property should be assessed at 52.7 % of that value or $527,000.
If the assessment in that example is $800,000 and you just bought the property for a million, the assessment is too high. So you need to be able to compute that or reach out to someone that can help you compute that. So you understand whether or not your assessment is too high or if your assessment is too low. Because if the assessment is too low, you may be looking at a school district filed appeal and the taxes may go up on that property. So understanding what the appropriate assessment value would be is very important because you pay property taxes every year.
And knowing if that's gonna change up or down can certainly factor into that purchase.
I want to back up. I don't want to bury the lead here. You had mentioned a couple things and if there are more tips, we can certainly get around to giving them. But it sounds like one of the key tips that you're offering here to someone who is in the process of purchasing a home, especially if that property is set to close on or after September 1st of this year. Don't wait to close in order to have the property tax appeal filed because you're going to have to pay an entire year of extra taxes if you do. Instead,
Speaker 1 (07:59.832)
Talk to the owner, the agents who are helping with the sale, and make sure that the current owner files an appeal before the deadline so that once you buy the property, you can take over the appeal and you can use the sale price as evidence in your appeal to hopefully make your 2026 taxes lower and not have to wait until 2027.
Correct. that's the important thing is being able to calculate where your assessment should be. So you better understand, do I have a case for a reduction or conversely, do I think my taxes might go up after I buy a property, which is something a lot of people don't consider. When I speak to people after a school district files an appeal, they say, I had no idea this was going to happen. I calculated my mortgage payments based on what I'm paying right now. I didn't know that the property taxes might go up significantly. This impacts my ability to afford this house.
So knowing that component when you're buying a property is really important because again, this is something that impacts you every single year for as long as you own that property. So it can be a significant benefit or a detriment depending on which way that would go.
One question I would have following up on that, suppose, is if you're in the process of purchasing a house, you should have some idea of whether your purchase price is likely to be something that gives you grounds to appeal versus if it's something where the taxing bodies are going to be particularly likely to appeal. And if you are setting a closing date and you think that the likely outcome here is that the taxing bodies are going to try to increase your taxes,
then there might be some value to closing in early September, for example, instead of in August, because now you've made your purchase on the other end of that deadline and the taxing bodies have the same deadline that the owners do to file their.
Speaker 2 (09:45.166)
Correct. And I think you bring up a good point is now property owners on the other side of the spectrum, the people that are under assessed actually do get a benefit to a certain extent. you buy your property, you know, if you buy your property in August, I think it would be unlikely that a school district would find it that quickly, although I don't know. But you do get the benefit of that lower assessment, presumably for an additional year before the school district does have an opportunity to file an appeal for potentially an increase.
So I think, again, the important thing is knowing where your assessment is on this property, what your purchase price would support the assessment to be, and understanding what risks you have, what potential case you might have. Because the common level ratio has gone down so much in the past couple of years, I am now seeing a lot more property owners having a strong case for an appeal, where usually, you know, five years ago, the majority of cases we handled were school district filed appeals.
The majority of cases I have now are owner filed appeals seeking reductions. So the landscape has definitely changed with appeals, but the most important part of it is knowing either way, are the taxes too low? Are they too high? What should they theoretically be? And then kind of understanding what timelines impact you, what the next steps would be. And again, property taxes, you pay them every year. It can make a big difference in terms of how much you can afford with a property.
You had talked about deadlines and you had said the deadline for your 2026 appeals is September 1st of this year, 2025. That's the last day you can file or do you have to file before that?
The last day you can file is September 1st, 2025. Appeal forms should become available, they are saying in July. So July and August and September 1st, if you wait till the last day, you can file appeals online to challenge 2026. If you do not file an appeal by September 1st, you gotta wait until next year.
Speaker 1 (11:37.878)
Let me be clear on this point. We've talked about deadlines, that is, when you run out of time. Can I appeal today for 2026 or when's the first day I can start filing 2026 appeals?
So they're indicating the Office of Property Assessments is indicating that appeal forms will become live on the county website in July. So I have been telling people July 1st is when we believe the appeal forms will become available for 2026. We are starting to get clients already on my list of appeals to file as soon as those appeal forms become available. And again, we have about a two month window this summer to file those 2026 appeals.
Hey, Bill, what a shit show. mean, if they don't release those forms until July, you know, the easy solution is to allow people to appeal a year early so they can appeal in advance if they want before the taxes are due, but also give people the appeal deadline as it existed. There would be no problem in having to appeal deadlines. You get the advantage if you file early to hear your case earlier. What do you think of that?
Well, I'm sure the administrative hassle of having multiple deadlines versus one is non-trivial, right? If we have to have twice as many appeals going on, that's going to cost some money. I don't know that having two systems makes sense. I see no reason why, if we're talking about just like literally the act of putting together a form, why that can't be done now. Why we have to compress it to a two-month window when there seems to me to be no reason that we can't be filing appeals for 2026 now, today.
Once the old deadlines passed, I should be able to start filing appeals for the next deadline to get redressed as quickly as possible and to minimize the chance that, I don't know, something happened in my life during those two months that makes it particularly hard to file an appeal or just that people who aren't educated on this don't know and by the time they figure it out, it's too late.
Speaker 2 (13:32.29)
And this is why I'm already starting to talk to people about 2026 appeals where they're saying, well, it's too early to retain you. And I tell them, no, it's not because once you're on my list, you know for sure that you will have a timely filed appeal in 2026 and you don't have to think about it again. You don't have to worry about these deadlines. I agree. wish the appeal forms were available now so I could just do that. But I think what they're trying to do is create a shorter appeal.
both window and time period during which they're scheduling hearings where they're trying to compress everything down. I don't know why because it's still not happening efficiently, but I think that that's kind of the goal. And as I said before, other counties in the state, I believe all of them have these type of appeal deadlines where they're actually prospective appeals in advance of the year. We're just not used to it here because it's never been done that way before. So I think in a couple years it won't be as big of a deal, but certainly right now there is a lot of confusion.
But Nicole, I have a different question on the buyers. What I've seen a couple of times and I'm wondering your experience with it is buyers who buy a home and did not know it was under appeal. Have you come across that?
I have, and unfortunately for some reason, title reports sometimes don't flag those either because we're waiting for a decision, so there's nothing really to flag, or there's an issue with something being wrong in the system with the filing or something like that, but I have definitely seen that, unfortunately, because property taxes run with the land. So say there's an appeal that's pending that's trying to increase the taxes, you come in, buy the property for more, all of a sudden,
you might be on the hook for taxes when you didn't even own the property for back years. that's another thing that I think is a really important factor of buying a house is knowing, again, what the taxes are, checking the docket, checking the appeal, the county website to see if any appeals are listed, things like that.
Speaker 3 (15:22.862)
If I'm buying a house, how do I check to see if the property I'm buying is under an existing tax appeal?
What I would do if it were my house would be to contact the office of property assessments and ask them that question. Just because the website is not always correct. And so I wouldn't defer to that. That is a good resource. So I might check that first just to see if an appeal is noted. Then I know for sure that one is noted. I would also check the docket, which is the Department of Court Records in Allegheny County. It is free for anyone to access, but you can type in a parcel identification number for a property to see if there's any tax liens.
pending litigation, things of that nature. Again, a title report is supposed to catch things at that level. But if you are just trying to make sure you're covering all your bases, that's a good resource. But definitely calling the Office of Property Assessments to ask them about the specific property, giving them the parcel number, they can check in their database if any appeals are open. That would be the best way, I think, to check whether or not anything is out
And to make it easy, it's 412-350-4636. And then the property record search is simply AlleghenyCounty.us.
Yeah, and you can type in any property address. There's an appeal status tab where if you open that, should say, you know, 2025 school district appeal. It will show you the status of it. But again, I would just caution people that that is not always correct. So I think calling them would probably be the best way to check.
Speaker 1 (16:54.462)
We talked about 2026 appeals, the deadlines for them when the appeal period essentially opens up for them. Nicole, I have one last question in this regard. We've talked many times over the past years because it's been at the heart of these major changes to the property tax system about the numerical ratio called the CLR, the common level ratio. What is the applicable CLR for 2026?
So we don't know what the common level ratio will be technically for 2026 appeals at this time. The state releases that number for every county in June. So by the end of June, this summer, before the appeal deadline for 2026, we will know what the ratio will be for 2026 appeals. From everyone I've talked to, from what I've been hearing, I think it will be close to the current ratio, which is 52.7, somewhere likely around 50%. But again, we will not know that official.
2026 common level ratio until June.
We didn't talk about this prospect yet today. Look, isn't all of this just going to get derailed by a reassessment? And what's going on on the reassessment and litigation front?
So a question I get a lot when I'm settling cases and clients are like, well, if a reassessment happens, I'm good, right? Which makes sense, but unfortunately, no. If and when a reassessment happens in Allegheny County, every single property in this county will receive a new number. It doesn't matter if you were just appealed the last year, doesn't matter if you were appealed 10 years ago, you will get a new number and that would basically represent the current market value of your property at the time the reassessment happens.
Speaker 2 (18:30.222)
So say it happens in 2028, just picking a year. You would get a new number like I would for my house and everyone would get for their properties saying, this is what the county thinks your property is worth as of 2028. So it wouldn't apply any ratio. We'd basically be starting over again. There are currently a bunch of lawsuits pending relating to a reassessment. The biggest one was filed by the city of Pittsburgh school district. They have a very large deficit based on large reductions in commercial properties.
which prompted them to file an appeal or basically a lawsuit to the court saying, Hey, we need a reassessment. we haven't had one since 2012. The numbers are wrong. They're all different for cat for commercial versus residential. There's a lot of errors. We basically need to start this over again. And they're currently fighting about that with the county among other parties. There has been a judge assigned from a different county to oversee it because all the judges here said they had a conflict. So it's taking a long time.
The judge has to come in from out of county for any actual oral arguments, things of that nature. And it's basically delaying everything. And while that has been pending, one of the big objections that was brought by the county was an issue of standing. Allegheny County basically said that the school district doesn't pay taxes. So they do not have standing to force a reassessment. So a couple of weeks ago, there was a new lawsuit filed by an individual property owner saying, I am asking for a reassessment.
Now that property owner is represented by the same law firm as the city of Pittsburgh school district. So it basically was a way, I think of the school district getting around this standing argument saying, fine, if you're not, if you are saying we don't have standing, this person certainly does because they pay taxes. So a couple of different things that are out there, it's taking a really long time. So certainly nothing's going to happen overnight, but at some point here we'll see. But I think everyone agrees we need a reassessment having to pay for it as another issue, but.
a couple kind of balls rolling that could potentially get us there.
Speaker 1 (20:32.674)
So we all agree broad strokes that look, sooner or later, there's going to have to be reassessment. You're not going to be able to keep the 2012 base year forever. There are various lawsuits filed, look, litigation like that is what caused the last two reassessments, right? The last two times Allegheny County reassessed, it might be more, but the two times in kind of my kind of practice and conscious memory that reassessing for forced, they were
court ordered because of a constitutional issue that continuing with the current process violated the uniformity clause of the Pennsylvania Constitution. look, if the kind of legislative and executive officials in this county don't schedule a reassessment on their own, eventually the court's going to do it. We just don't know when, correct?
That's kind of, mean, yes, I think so. you know, the more solicitors I talk with both property owner and tax entity, um, related, mean, everyone agrees that our system doesn't work. Everyone I think agrees on that very base level. And one of the things we're seeing now, which is affecting everyone is because we haven't had reassessments, all the millage rates are going up. The Allegheny County millage rate went up 36 % this year. So the little old lady that has lived in her house for 50 years.
that has never been involved in an appeal, her taxes just went up for county tax purposes by 36%. So it's starting to impact everyone. That doesn't even account for the increases people will see in their borough and school district taxes, because without a reassessment, those numbers just keep going up, up, up. They never go down. So I think as people start feeling the pressure a little bit more, it's going to get some more attention. I've had a lot of people reach out to me in the past couple of weeks saying,
Why didn't my assessment go up? What's going on? And I look, nothing happened to their assessment. Their taxes are just going up because taxes are going up. So I think more people are starting to understand that if we don't have regular reassessments, everyone will be negatively impacted by it. It's not like anyone skates by. So I think as that continues, the fallout continues with that and we start seeing tax bills hike up, which will continue to happen. I think it's going to gain more steam and hopefully I think
Speaker 2 (22:46.582)
you know, again, I think everyone agrees that our current system isn't working. We need to fix it. Hopefully, eventually we can agree that there is a way to do that.
You're talking to somebody who has lived through two, both reassessments. Simmons is old.
So, you know, having lived through both reassessments, it's been chaos for 25 years. And they've never tried to fix the problem in an intelligent manner, you know, trying to postpone the deadline in advance so you can appeal before your taxes are due makes sense. But Nicole, you know, the biggest winners in all of this, tell me if you agree or disagree is the people who have been in their home since 2012 and have a favorable assessment.
and whose property has doubled in value or more in 15 years. they're just, know, other people are carrying their burden to a large degree. Do you agree?
I think the biggest winners are people that have lived in their house since 1980 and the property values have maybe quadrupled and they were low in the reval. So they're just paying nothing while their neighbor who just sold for, you know, five times whatever they paid for their house, they're going to get appealed. Their taxes are going to be triple. And, you know, there's no perfect way of doing it other than just doing it regularly because then the cost is less. The shock of it is less. That's what a lot of other places do because it makes sense to do it that way. But
Speaker 2 (24:10.08)
It will cost money to get a system like that in place, which is where the problem comes in, because no one has that money right now and everyone wants to point at other people instead of actually getting down to fixing this problem.
Alright everyone, for your time. should do it for this episode of I Strenuously Object. Hopefully you learned something or got caught up on the current events in the world of property tax appeals. Please subscribe, rate, review the podcast, tell your friends to check us out. If you have any questions about property tax appeals, if you have something for our mailing it in mailbag segment, or any feedback whatsoever for the podcast, can email us at iobject at pghfirm.com. We are on Instagram at istrenuouslyobject.com.
podcast. For more information on tax appeals or any other legal matters, please visit our website. That's Flaherty, Fardo, Rogal, and Amick and the website is pghfirm.com. Until next time, some parting advice.
believe that it doesn't matter where your home is because home is where your home is. And we may lose this family, but we'll always have our family because we're Brady's. And this family is our home. We'll always have our family.
is where it started. This house.
Speaker 1 (25:17.548)
That's why we're keep our home as long as we're it. Even if we lose our house, we're still Brady's.
have our
Speaker 2 (25:24.45)
Your father's right.