HomeMy WebLinkAboutAgenda - 11-17-1998 - 9cORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: November 17, 1998
Action Agenda
Item No. R ~ C
SUBJECT: Frances Mikles Property Tax Refund Request
DEPARTMENT: Assessor's Office
PUBLIC HEARING: (Y/N)
BUDGET AMENDMENT: (Y/N) 1~0 ~:'
ATTACHMENT(S):
Resolution
Tax Refund Requests
INFORMATION CONTACT:
John Smith, Jr., ext 2101
TELEPHONE NUMBERS:
Hillsborough 732-8181
Chapel Hill 968-4501
Durham 688-7331
Mebane 227-2031
PURPOSE: To consider adoption of refund resolution related to 1 request for property tax refund.
BACKGROUND: General Statute 105-381(b), "Action of Governing Body" provides that "upon
receiving a taxpayer's written statement of defense and request for release or refund, the governing
body of the Taxing Unit shall within 90 days after receipt of such a request determine whether the
taxpayer has a valid defense to the tax imposed or any part thereof and shall either release or refund
that portion of the amount that is determined to be in excess of the correct liability or notify the
taxpayer in writing that no release or refund will be made".
At the November 4, 1998 meeting, the Board considered a request from Mrs. Frances Mikles to
refund a portion of property taxes that she paid for tax years 1993 through 1997. The requested
refund totals $759.99. The Assessor's office ascertained that she had been improperly taxed for
288 square feet of heated space, which should have been taxed instead as an unheated carport. This
error has been corrected for 1998 and subsequent tax years. The County Attorney advised that the
measurement error involved in this case is not a "clerical error" within the meaning of the applicable
statute, and that there is not a statutory basis for granting the requested refund.
The Board's vote was 2-2 on a motion to grant the refund request by Mrs. Mikles. The Board
indicated that it would like to take this issue up again when all Board members will be present at the
November 17 meeting. Per the County Attorney's advice, parliamentary procedure requires that
one of the Board members who did not vote in favor of the November 4 motion (Commissioners
Carey, Crowther, or Gordon) must make a motion to reconsider this item and that motion must be
carried in order for the Board to reconsider the tax refund request of Mrs. Mikles. If the Board
adopts such a motion, the Board would then conduct a separate vote on the refund request itself.
RECOMMENDATION: As the Board decides.
?a
Map Nbr:4.42E..13
Tract Nbr: 421609
Account Nbr: 80810
Rate Code: 23
Name: Frances Mikles
& Toni Mikles
Address: 109 Nutbush Ct.
Hillsborough, NC 27278
Action Requested: Request property tax refund for 1993 - 1997.
Recommendation: Disapprove total property tax refund of $759.99
Explanation: Home was listed with dimensions of 52 ft x 24 ft. The true dimensions
are 40 ft x 24 ft. The owner is requesting refund based on incorrect measurements. Error
does not fall under the valid defense for a refund as defined in G.S. 105-381 (a) (1):
a tax imposed through clerical error, an illegal tax, or a tax levied for an illegal purpose.
See attached letter from county attorney Geoff Gledhill.
Reference: General Statute 105-381(a)(1)
NORTH CAROLINA
ORANGE COUNTY
REFUND RESOLUTION (Denial)
Whereas, North Carolina General Statutes 105-381 allows for the refund of taxes when the Board
of County Commissioners determines that a taxpayer applying for the refund has a valid defense to the tax
imposed; and
Whereas, the properties listed in each of the attached "Request for Property Tax Refunds" has
been taxed and the tax has been collected: and
Whereas, as to each of the properties listed in the Request for Property Tax Refunds, the taxpayer
has timely applied in writing for a refund of the tax imposed but has not presented a valid defense to the
tax imposed as indicated on the Request for Property Tax Refunds.
NOW, THEREFORE, IT IS RESOLVED BY THE BOARD OF COUNTY
CONIlVIISSIONERS OF ORANGE COUNTY THAT the property tax refund(s) recommended for
denial are denied.
Upon motion duly made and seconded, the foregoing resolution was passed by the following
votes:
Ayes: Commissioners
Noes:
I, Beverly A. Blythe, Clerk to the Boazd of Commissioners for the County of Orange, North
Carolina, DO HEREBY CERTIFY that the foregoing has been cazefully copied from the recorded minutes
of the Boazd of Commissioners for said County at a regulaz meeting of said Board held on
said record having been made in the Minute Book of the minutes of said Boazd,
and is a true copy of so much of said proceedings of said Board as relates in any way to the passage of the
resolution described in said proceedings.
WITNESS my hand and the corporate seal of said County, this day of
199
3
Clerk to the Board of Commissioners
NORTH CAROLINA
ORANGE COUNTY
REFUND RESOLUTION (Approval)
Whereas, North Carolina General Statutes 105-381 allows for the refund of taxes when the Board
of County Commissioners determines that a taxpayer applying for the refund has a valid defense to the tax
imposed; and
Whereas, the properties listed in each of the attached "Request for Property Tax Refunds" has
been taxed and the tax has been collected: and
Whereas, as to each of the properties listed in the Request for Property Tax Refunds, the taxpayer
has timely applied in writing for a refund of the tax imposed and has presented a valid defense to the tax
imposed as indicated on the Request for Property Tax Refunds.
NOW, THEREFORE, IT IS RESOLVED BY THE BOARD OF COUNTY
COMMISSIONERS OF ORANGE COUNTY THAT the recommended property tax refund(s) are
approved.
Upon motion duly made and seconded, the foregoing resolution was passed by the following
votes:
Ayes: Commissioners
Noes:
I, Beverly A. Blythe, Clerk to the Board of Commissioners for the County of Orange, North
Carolina, DO HEREBY CERTIFY that the foregoing has been cazefully copied from the recorded minutes
of the Boazd of Commissioners for said County at a regulaz meeting of said Boazd held on
said record having been made in the Minute Book of the minutes of said Board,
and is a true copy of so much of said proceedings of said Board as relates in any way to the passage of the
resolution described in said proceedings.
WITNESS my hand and the corporate seal of said County, this day of
199
3a
Clerk to the Board of Commissioners
LAW OFFTCFS
COLEMAN, GLEDHILL & HARGRAVE
A FROFESSIONAL CORPORATION
129 E. TRYON STREET
P. O. DRAWER 1529
HILLSBOROUGH, NORTH CAROLINA 27278
919.732.2196
FAX 929.732.7997
September 11, 1998
Mr. John Smith
Orange County Tax Assessor
Post Office Box 8181
Hillsborough, North Carolina 27278
FROM THE DESK OF
GEOFFREY E. GLEDHILL
RE: Measurement Error as Basis for a Tax Refund
Dear John:
This letter confirms my view that appraisal mistakes,
measurement or otherwise, do not give a basis for a release or
refund of property taxes. They do give a basis for a prospective
correction under G.S. § 105-287. A measurement mistake does not
create an illegal tax on the theory that "the property taxed 'was
not there.'" On the other hand if a structure is determined to
not be there or to have been removed, then a release or refund
would be appropriate under the illegal tax authority.
I recognize that the distinction between the two situations
is a "fine" one. However, I think it is the right one if Orange
County is to avoid converting every measurement mistake made in
the tax assessment process into an illegal tax.
Very truly yours,
GLEDHILL & HARGRAVE, P.C.
E. Gledhill
GEG/lsg
4
mydocuments\smith4.ltr
Orange County Tax Assessor's Office 5
PO Box 8181
Hillsborough, NC 27278
Orange County Tax Office
October 2, 1998
Frances Mikles
109 Nutbush Ct.
Hillsborough, NC 27278
Dear Ms. Mikles:
Re: 4.42E..13
This is in response to your letter requesting a property tax refund
due to a significant measurement error in the listing of your home.
Based on my inspection and re-measurement of your home, I found that you
have been taxed for 288 square feet more than actually exists. This error
occurred when the county appraiser measured your home and included the
12-foot carport, located on the end of your home, as part of the heated
square feet measurement. As a result, your home has been listed with
measurements of 24 x 52 instead of the correct measurements of 24 x 40.
On the day that I inspected your home and verified the error, you and I
spoke about the possibility of a tax refund. I explained that once your written
request for refund was received, I would review the applicable statutes
governing refunds. I also explained that, if a refund could be made then you
would be entitled to a refund equal to up to five years of overpayment.
My review of the laws governing refunds, lead me to believe that there was
a possibility of a refund but that it was somewhat of a gray area. I say this
since the error, in my opinion, was clearly an appraisal error which is not
refundable, there was the possibility that we could consider the taxation of
288 non-existent square feet to be a duplication of taxation which is
refundable. In the process that we go through in qualifying refunds, the
county attorney reviewed the details of the refund request and indicated to
me that the error is appropriately considered to be an appraisal error rather
than an error of duplication or double taxation.
In conclusion, your tax records have been corrected for 1998 and your
tax bill has been adjusted as well. Related to the refund request, I have
decided to recommend to the Board Of County Commissioners that the five
Should you have questions please call John Smi
732-8181 ext 2101. .
October- 2, 1994
Pcrge 2
year refund totaling $759.99 be denied. It is my expectation that your
refund request will be considered during the Commissioners meeting
scheduled for November 4th, 1998. I am recommending placing it on the
agenda for this meeting so that it will be most convenient for you to attend
since the meeting will be in Hillsborough, in the new courthouse, in the newly
constructed F. Gordon Battle Courtroom, at 7:30 PM. I know that the
commissioners would be very interested in hearing from you on this issue
and I hope that you will be able to attend.
I hope you understand that refund decisions are some of the most
difficult decisions that I have to make. There are several reasons as to why
this is. One reason is that the laws governing refunds are often gray, there
is very little case law to help us in determining the proper decision, plus tax
laws often are simply "not fair" to the taxpayer. Another serious
consideration is also the personal liability that the laws of North Carolina
place on the commissioners when they approve a refund. Since each
commissioner can be held personally liable for refunds they approve, that
are not properly approved under the statutes, each refund has to be carefully
considered.
Ultimately, only the commissioners can approve or deny a refund
request such as yours. Should the recommendation to deny be accepted by
the board then you still have the opportunity to be heard by the North
Carolina Property Tax Commission and by the courts of the state.
Whatever the outcome, the county commissioners, and I understand your
concern and the unfairness of the situation. Please keep in touch and I
personally will continue working in every capacity possible to assist you.
Sincerely
6
Smith,` AE
range County