Choe v. From the Decision of the Philadelphia Bd. of Revision of Taxes

In Choe v. From the Decision of the Philadelphia Bd. of Revision of Taxes, Appellants, who are current or former owners of condo units, appealed from an order of the Court of Common Pleas that denied Appellants’ appeal from a decision of the Philadelphia’s Board of Revision of Taxes (BRT). BRT denied Appellants’ real estate market value appeals for tax years 2014 and 2015, wherein Appellants challenged the City’s Office of Property Assessment’s (OPA) termination of a 10-year tax abatement for each of the individual condo units effective December 31, 2013. The Pennsylvania Commonwealth Court affirmed and ruled that, based upon the plain and unambiguous language of BRT’s December 8, 2005 letters and the date on which Developer informed BRT that the improvements to the units’ had been completed, the 10-year term of the tax abatement granted on the individual units began on January 1, 2004, and ended on December 31, 2013. Appellants were not entitled to equitable relief in the form of a 10-year tax abatement.

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