PROPERTIES CORRECTLY VALUED FOR TRANSFER TAX
The Commonwealth Court en banc held that a taxpayer correctly
valued 3 properties that were part of a sale of 141 properties in a
number of states. City of Philadelphia v. Tax Review Board, ex
rel. First State Investors 3300 LLC, No. 792 C.D. 2008 (Pa.
Commw. July 30, 2009 (en banc) (unreported). Wachovia Bank agreed
to sell the properties to a subsidiary of a REIT. The properties
were to be sold at book value. Some of the space was to be leased
back to Wachovia. The City agreed that the transaction was an arms
length sale, but believed that the values of the 3 properties in
Philadelphia were incorrectly stated. The book values assigned to
the property were not the same as what the Commonwealth calls
computed value, which is the assessed value for real
estate tax purposes times the common level ration factor, a number
generated by a state agency intended to represent the actual ratio
of assessed market values in the city to
