Angelo v. New Castle County Board of Assessment Review, N17A-06-008 VLM

Property at 611 Southerness Drive (Townsend, DE) purchased in 2007; deed later placed in trusteeship including Appellant.
New Castle County assessed the property at $98,900 (land $10,900; structure $88,000).
On April 11, 2016, Appellant Ronald Angelo Sr. appealed, seeking an assessment of $30,000 (and at hearing testified the property had no value), but submitted no appraisal or comparable sales showing fair market value as of the statutory base date (July 1, 1983).
Appellant attached a list of 15 alleged code, deed, and other legal violations and administrative complaints (FOIA requests, ADA complaint), but provided no documentary proof of overvaluation or invalid deed with his appeal.
The Assessment Division notified Appellant of deficiencies and asked for comparable sales or a July 1, 1983 value; Appellant did not supply them.
The Board denied the appeal for lack of competent evidence of substantial overvaluation and for failure to include required evidence with the appeal form; Appellant appealed to the Superior Court, which affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Appellant met burden to show substantial overvaluation of assessed value as of July 1, 1983	Angelo argued the assessment was improper and the deed/assessment process invalid; alleged many violations that, he claimed, reduced value to $30,000 or zero	County argued Angelo produced no appraisal or comparable sales and submitted no evidence of market value as of the base date; assessment presumed correct	Court held Angelo failed to present competent evidence of substantial overvaluation; affirmed Board denial
Whether the Board improperly prevented Angelo from presenting evidence or addressing alleged deed/code violations at the hearing	Angelo contended the Board wouldn’t allow him to present evidence despite listing violations and claiming evidence existed with other agencies	County maintained Board rules require evidence be disclosed with appeal form and that Angelo did not submit supporting documents; unrelated claims are not part of the property tax appeal process	Court held Board acted within its rules; evidence must be submitted with the appeal and the assessment board is not the forum for collateral claims; no reversible error

Shahin v. City of Dover Bd. of Assess. Appeals, 149 A.3d 227 (Del. 2016) (property owner bears burden to show substantial overvaluation; assessment presumed correct)
Tatten Partners, L.P. v. New Castle Cty. Bd. of Asses. Review, 642 A.2d 1251 (Del. Super. Ct. 1993) (Board of Assessment lacks authority to adjudicate unrelated statutory claims; procedural limits on joining other claims)
E.I. DuPont De Nemours & Co. v. Faupel, 859 A.2d 1042 (Del. Super. Ct. 2004) (discusses limits of administrative review and proper forum for non-assessment claims)