Wyner v. District of Columbia
411 A.2d 59 (1980)
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Rule of Law:
Summary judgment is improper in a property tax assessment appeal when a taxpayer's sworn affidavit creates a genuine dispute of material fact regarding the property's classification, which the taxing authority has based only on an inference.
Facts:
- A previous owner of a property applied for permits to make repairs and improvements to a structure that was classified as a single-family residence.
- Steven Wyner subsequently purchased the property.
- The District of Columbia taxing authority inferred that the permitted construction work was completed and had converted the property into a multi-family unit.
- Based on this inference, the District substantially increased the property's assessed value for the 1979 fiscal year.
- In September 1978, Wyner received the tax bill with the increased assessment.
- Wyner asserted in a sworn affidavit that the property was, in fact, a single-family dwelling.
- Wyner failed to timely apply for a separate homestead exemption after receiving notice of the increased assessment.
Procedural Posture:
- Steven Wyner appealed his 1979 property tax assessment by filing a suit against the District of Columbia in the Superior Court (trial court).
- The District of Columbia filed a motion for summary judgment.
- Wyner filed a cross-motion for summary judgment.
- The Superior Court granted the District of Columbia's motion for summary judgment and denied Wyner's motion.
- Wyner, as appellant, appealed the trial court's decision to the District of Columbia Court of Appeals, the intermediate appellate court. The District of Columbia is the appellee.
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Issue:
Does a taxpayer's sworn affidavit stating a property is a single-family dwelling create a genuine issue of material fact sufficient to preclude summary judgment when the taxing authority's assessment is based solely on an inference from construction permits issued to a previous owner?
Opinions:
Majority - Nebeker, Associate Judge
Yes. A taxpayer's sworn affidavit creates a genuine issue of material fact that precludes summary judgment. The court reasoned that the District of Columbia's entire basis for reassessing the property as a multi-family unit was an inference drawn from construction permits issued to a prior owner. The District presented no direct evidence that the permitted work was actually completed. In contrast, the current owner, Wyner, submitted a sworn affidavit stating the property is a single-family dwelling. This direct assertion of fact contradicts the District's inference, creating a material factual dispute that cannot be resolved on summary judgment. Under Super.Ct.Civ.R. 56, summary judgment is only appropriate when there is no genuine dispute of material fact, and tax assessment appeals in Superior Court are trials de novo, requiring the court to hear evidence and make its own findings.
Analysis:
This decision reinforces the fundamental procedural rule that summary judgment cannot be used to resolve factual disputes. It establishes that a taxing authority cannot rely solely on inferences from past administrative actions, like issuing permits, to justify a tax assessment when faced with a taxpayer's direct, sworn contradictory evidence. The ruling underscores the de novo nature of tax appeals, obligating courts to conduct a full factual inquiry rather than deferring to the assessor's initial conclusions. This precedent protects taxpayers by requiring the government to produce concrete evidence, not just assumptions, to support its assessments in court when a factual issue is raised.
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