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Maryland Court Relaxes Stand on Date of Finality

by Tom Branham, Washington D.C., September 2015


When Maryland real estate is assessed for property taxes, comparable sales are typically only considered as of the January 1 assessment date, also known as the date of finality.


A ruling by the Court of Special Appeals allows sales after the date of finality to be considered in certain circumstances.

Court Ruling


In Supervisor of Assessments v. Lane, the Court of Special Appeals ruled that while state law requires property be valued as of the date of finality, it does not specify just how it must be done.


The Court of Special Appeals three-judge panel explained that the Department of Assessments and Taxation and its local taxing authorities have followed the practice of considering sales after the date of finality to value property when such sales are found to be reasonably close in time and otherwise comparable. Such information is considered and weighed along with all other relevant evidence to correctly determine a property's assessed value.

What This Means to Property Owners

The date of finality rule seemed to represent a firm date that limited which comparable sales could be used in appeals. Nothing beyond the date of finality could be considered because the valuation had to be as of January 1.


Following the Lane decision, taxpayers should understand that sales, which are close in time to the date of finality, can be considered. This may help solidify an appeal position when sales after January 1 support a lower valuation.