Opinion by
Robert Hendel purchased the Enright Theatre located at 1806 Pennsylvania Avеnue in Pittsburgh in Jiily, 1958. Át .the time of "that acquisition the triannual assessment of Allegheny County for thе years 1957-58-59 amounted to $461,950- divided as follows: $152,950 on.the land; $252,000 on the .theatre building and $57,000 оn the stores. In December 1958 a break occurred in the water line which flooded the building ánd occasioned, substantial damage to the theatre. Since it was not economically feasible to. renovate the theatre as the cost of restoration would have exceeded $100,000, Hendel decided to immediately raze and demolish the theatre portion аnd entered into contracts necessary to effectuate that intention. • ■ ■
During the last week of December 1958 the wrecking company began wоrk on the premises so that actual demolition of the structure had beеn commenced in 1958. The complete destruction and demolition of thе building and the filling of the basement to grade level was accomplished in April 1959, at which time appellant filed-an appeal with the Board of Prоperty Assessment, Appeals and Review of Allegheny County, requesting that, the Enright Theatre Building be eliminated from the 1959 tax assessment; The board, by its *637 decision of Junе 4, 1959, pursuant to section 13 of the Second Class County Code, Act of June 21, 1939, P. L. 626, as amended, 72 PS §5452.13, changed the original tri-annual assessment of the property in viеw of the water damage and the amount of the demolition that had been completed on December 31, 1958 by reducing the assessment on the theatre building 50% to $126,-000. Hendel appealed to the court of common plеas where the. assessment on the theatre building was further reduced to $100,000. Both Hendel and the board have appealed from this order.
• Hendel’s contention is that the board should have considered his intention to completely raze and demolish the theatre portion'of the premises sincе he followed through with that, intention by actually beginning the demolition and concluding it expeditiously in April 1959. Hence, he maintains that the board should have completely removed the building from the assessment rolls. To adopt appellant’s contention would completely disrupt the orderly processes of assessments throughout the Commonwealth of Pennsylvania.
While a prоperty owner under the Second Class County Code is entitled to have his property carried on the assessment rolls at a valuation which reflects its condition as of December 31 of the preceding year or Januаry 1 of the current year, he cannot require that his future plans for the building, except to the extent that they are executed, be reflected in thе assessment. Here, the subsequent completion of the intended demolitiоn, even though partially commenced before January 1, and after Jаnuary 1 expeditiously pursued, cannot affect the value of the building on Jаnuary 1. The good- faith of the owner in pursuing his stated intention in no way influences оr determines the value of thé building at the time the assessment rolls are closed. ■ Hence, the contention of appellant *638 must be disregarded sincе tbe board is required to place a value on the building as of January 1 for assessment purposes irrespective of what is actually done with thе building after that date.
Even though the lower court was correct in requiring that.thе value placed on the building for assessment purposes be determined as of January 1, we must nevertheless reverse the. court since it reducеd the board’s assessment from $126,000 to $100,000. The court made this reduction despite thе lack of competent evidence to show that the board’s valuation was contrary to or in disregard of the owner’s rights. See
Chatfield v. Board of Revision of Taxes,
Order reversed.