The Philadelphia Office of Property Assessment (OPA) has reviewed the assessed values of all commercial and industrial real estate in Philadelphia, and earlier this year, many owners of commercial and industrial real estate received notices from the OPA showing very significant increases in their 2018 real estate tax assessments.

To protect your legal right to contest an assessment, an appeal must be filed with the Philadelphia Board of Revision of Taxes by Monday, October 2, 2017. Be aware that filing a "first-level review" with the OPA alone does not secure appeal rights. Additionally, as we witnessed last October, property owners who are satisfied with their 2018 assessment still may be subject to an appeal filed by the Philadelphia School District arguing that an assessment is too low.

Notwithstanding the School District's newly aggressive position regarding filing real estate assessment appeals, its ability to do so well may be limited. In Valley Forge Towers Apts. N, LP et al. v. Upper Merion Area School District, the Pennsylvania Supreme Court restricted the ability of a school district to appeal real estate tax assessments. Earlier today, in fact, Judge Idee Fox of the Philadelphia Court of Common Pleas quashed Philadelphia School District assessment appeals on the basis that they ran afoul of the Supreme Court's ruling in Valley Forge Towers.