NC General Statutes

N.C. Gen. Stat. § 105-287 (2026)

Changing appraised value of real property in years in which general reappraisal is not made

✓ current as of July 2026

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(a) In a year in which a general reappraisal of real property in the county is not made under G.S. 105-286, the property shall be listed at the value assigned when last appraised unless the value is changed in accordance with this section. The assessor shall increase or decrease the appraised value of real property, as determined under G.S. 105-286, to recognize a change in the property's value resulting from one or more of the following reasons:

(1) Correct a clerical or mathematical error.

(2) Correct an appraisal error resulting from a misapplication of the schedules, standards, and rules used in the county's most recent general reappraisal.

(2a) Recognize an increase or decrease in the value of the property resulting from a conservation or preservation agreement subject to Article 4 of Chapter 121 of the General Statutes, the Conservation and Historic Preservation Agreements Act.

(2b) Recognize an increase or decrease in the value of the property resulting from a physical change to the land or to the improvements on the land, other than a change listed in subsection (b) of this section.

(2c) Recognize an increase or decrease in the value of the property resulting from a change in the legally permitted use of the property.

(3) Recognize an increase or decrease in the value of the property resulting from a factor other than one listed in subsection (b).

(b) In a year in which a general reappraisal of real property in the county is not made, the assessor may not increase or decrease the appraised value of real property, as determined under G.S. 105-286, to recognize a change in value caused by:

(1) Normal, physical depreciation of improvements;

(2) Inflation, deflation, or other economic changes affecting the county in general; or

(3) Betterments to the property made by:

a. Repainting buildings or other structures;

b. Terracing or other methods of soil conservation;

c. Landscape gardening;

d. Protecting forests against fire; or

e. Impounding water on marshland for non-commercial purposes to preserve or enhance the natural habitat of wildlife.

(c) An increase or decrease in the appraised value of real property authorized by this section shall be made in accordance with the schedules, standards, and rules used in the county's most recent general reappraisal. An increase or decrease in appraised value made under this section is effective as of January 1 of the year in which it is made and is not retroactive. The reason for an increase or decrease in appraised value made under this section need not be under the control of or at the request of the owner of the affected property. This section does not modify or restrict the provisions of G.S. 105-312 concerning the appraisal of discovered property.

(d) Notwithstanding subsection (a), if a tract of land has been subdivided into lots and more than five acres of the tract remain unsold by the owner of the tract, the assessor may appraise the unsold portion as land acreage rather than as lots. A tract is considered subdivided into lots when the lots are located on streets laid out and open for travel and the lots have been sold or offered for sale as lots since the last appraisal of the property. (1939, c. 310, ss. 301, 500; 1953, c. 970, s. 5; 1955, c. 901; c. 1100, s. 2; 1959, c. 682; c. 704, s. 2; 1963, c. 414; 1967, c. 892, s. 7; 1969, c. 945, s. 1; 1971, c. 806, s. 1; 1973, c. 695, s. 10; c. 790, s. 2; 1987, c. 655; 1997-226, s. 4; 2001-139, s. 2; 2008-146, s. 1.2.)

Article 15.

Duties of Department and Property Tax Commission as to Assessments.

Notes of Decisions

Cited in 33 cases, 1960–2020 · leading case: In Re Appeal of Blue Ridge Mall LLC, 713 S.E.2d 779 (N.C. Ct. App. 2011).

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In Re Appeal of Blue Ridge Mall LLC, 713 S.E.2d 779 (N.C. Ct. App. 2011). · cites it 7× “In a year in which a general reappraisal is *272 not made, “[a]n increase or decrease in the appraised value of real property authorized by this section shall be made in accordance with the schedules, standards, and rules used in the county’s most recent general reappraisal,"…”

In Re the Appeal of Corbett, 558 S.E.2d 82 (N.C. 2002). · cites it 55× “h the application of the County’s schedules, standards and rules would have been the correct method of valuation had the property (1) been valued as part of a countywide general or horizontal adjustment, provided for by section 105-286; or (2) had the division of their property…”

In re the Appeal of Dickey, 431 S.E.2d 203 (N.C. Ct. App. 1993). · cites it 16× “00 for the tax year 1989, and that, under the provisions of N.C.G.S. § 105-287, the Assessor was authorized to reappraise the house in 1990, but that such reappraisal is effective as of 1 January of the year in which it is made and is not retroactive.”

Thrash v. City of Asheville, 393 S.E.2d 842 (N.C. 1990). · cites it 6× “” N.C.G.S. § 105-287(b)(4) (1985). See also N.”

In Re Appeal of the Lane Co.-Hickory Chair Div., 571 S.E.2d 224 (N.C. Ct. App. 2002). · cites it 3× “2d at 59 (quoting N.C.G.S. § 105-287(c) (2001)). We agree that a post-octennial sale of the property in question cannot be used for a valuation adjustment.”

Mao/pines Assocs., Ltd. v. New Hanover Cty. Bd. of Equal., 449 S.E.2d 196 (N.C. Ct. App. 1994). · cites it 6× “Once real property has been appraised for taxation, it continues to be listed at the appraised valuation figure until next formally appraised, see G.”

In re Hotel L'Eur., 448 S.E.2d 865 (N.C. Ct. App. 1994). · cites it 14× “, who at that time owned three parcels of commercial property in downtown Durham, requested a revaluation of those properties, pursuant to N.C. Gen. Stat. § 105-287 . Subsequent to that request and sometime prior to the appeal to this Court, Triangle V, Limited Partnership,…”

In re the Appeal of Allred, 496 S.E.2d 405 (N.C. Ct. App. 1998). · cites it 16× “” N.C. Gen. Stat. § 105-287 (b)(2) (1995). In a separate but related argument, respondent contends that the Commission transgressed its statutory authority by considering the 1993 sale from Gai-Tronics to petitioners in determining the validity of the assessments at issue in…”

Appeal of Philip Morris USA, 503 S.E.2d 679 (N.C. Ct. App. 1998). · cites it 2× “" N.C. Gen.Stat. § 105-287(c) (1987). Cabarrus County's most recent reevaluation year was 1991, thus the parties stipulated that the value of the improvements to the land should be appraised at what those improvements would have been worth on 1 January 1991, rather than…”

In Re North Wilkesboro Speedway, Inc., 582 S.E.2d 39 (N.C. Ct. App. 2003). · cites it 2× “Specifically, the County argues that the appeal before the Commission should have been dismissed because taxpayer failed to carry its burden of showing that the County employed an arbitrary or illegal method of appraising the Property, that a reappraisal of the Property for the…”

Asheville Indus., Inc. v. City of Asheville, 436 S.E.2d 873 (N.C. Ct. App. 1993). · cites it 2× “Classification of subdivisions are limited to tracts “that have been divided into lots that are located on streets laid out and open for travel and that have been sold or offered for sale as lots.”

In re Ocean Isle Palms LLC, 366 NC 351, 749 S.E.2d 439 (N.C. 2013). · cites it 15× “When the challenged reassessment took place in 2008, section 105-286(c) addressed the value to be assigned to real property during a year when that property was not subject to reappraisal and provided in pertinent part that “[i]n years in which real property within a county is…”

Show all 33 citing cases →

— N.C. Gen. Stat. § 105-287(a) — 9 cases

In Re the Appeal of Corbett, 558 S.E.2d 82 (N.C. 2002). “h the application of the County’s schedules, standards and rules would have been the correct method of valuation had the property (1) been valued as part of a countywide general or horizontal adjustment, provided for by section 105-286; or (2) had the division of their property…”

In re Ocean Isle Palms LLC, 366 NC 351, 749 S.E.2d 439 (N.C. 2013). “When the challenged reassessment took place in 2008, section 105-286(c) addressed the value to be assigned to real property during a year when that property was not subject to reappraisal and provided in pertinent part that “[i]n years in which real property within a county is…”

In re Appeal of Ocean Isle Palms LLC, 723 S.E.2d 543 (N.C. Ct. App. 2012).

In the Matter of Allred, 519 S.E.2d 52 (1999).

In re Appeal of Corbett, 530 S.E.2d 90 (N.C. Ct. App. 2000).

— N.C. Gen. Stat. § 105-287(a)(2) — 5 cases

In re: Lowe's Home Ctrs. (N.C. Ct. App. 2020).

In Re Schwartz & Schwartz, Inc., 603 S.E.2d 852 (N.C. Ct. App. 2004).

In re Appeal of Ocean Isle Palms LLC, 723 S.E.2d 543 (N.C. Ct. App. 2012).

— N.C. Gen. Stat. § 105-287(a)(3) — 5 cases

In re Appeal of Corbett, 530 S.E.2d 90 (N.C. Ct. App. 2000).

In Re Schwartz & Schwartz, Inc., 603 S.E.2d 852 (N.C. Ct. App. 2004).

In re Appeal of Schwartz & Schwartz, Inc., 166 N.C. App. 744 (N.C. Ct. App. 2004).

In re Johnson, 415 S.E.2d 108 (N.C. Ct. App. 1992).

— N.C. Gen. Stat. § 105-287(a)(l) — 1 case

— N.C. Gen. Stat. § 105-287(b) — 5 cases

In re the Appeal of Allred, 496 S.E.2d 405 (N.C. Ct. App. 1998). “” N.C. Gen. Stat. § 105-287 (b)(2) (1995). In a separate but related argument, respondent contends that the Commission transgressed its statutory authority by considering the 1993 sale from Gai-Tronics to petitioners in determining the validity of the assessments at issue in…”

In re Appeal of Corbett, 530 S.E.2d 90 (N.C. Ct. App. 2000).

In the Matter of Allred, 519 S.E.2d 52 (1999).

In re Johnson, 415 S.E.2d 108 (N.C. Ct. App. 1992).

— N.C. Gen. Stat. § 105-287(b)(2) — 3 cases

In Re Schwartz & Schwartz, Inc., 603 S.E.2d 852 (N.C. Ct. App. 2004).

In re Appeal of Schwartz & Schwartz, Inc., 166 N.C. App. 744 (N.C. Ct. App. 2004).

— N.C. Gen. Stat. § 105-287(b)(4) — 2 cases

Thrash v. City of Asheville, 393 S.E.2d 842 (N.C. 1990). “” N.C.G.S. § 105-287(b)(4) (1985). See also N.”

Asheville Indus., Inc. v. City of Asheville, 436 S.E.2d 873 (N.C. Ct. App. 1993). “Classification of subdivisions are limited to tracts “that have been divided into lots that are located on streets laid out and open for travel and that have been sold or offered for sale as lots.”

— N.C. Gen. Stat. § 105-287(b)(5) — 1 case

In re Butler, 352 S.E.2d 232 (N.C. Ct. App. 1987).

— N.C. Gen. Stat. § 105-287(b)(6) — 1 case

In re Hotel L'Eur., 448 S.E.2d 865 (N.C. Ct. App. 1994). “, who at that time owned three parcels of commercial property in downtown Durham, requested a revaluation of those properties, pursuant to N.C. Gen. Stat. § 105-287 . Subsequent to that request and sometime prior to the appeal to this Court, Triangle V, Limited Partnership,…”

— N.C. Gen. Stat. § 105-287(c) — 7 cases

In Re Appeal of the Lane Co.-Hickory Chair Div., 571 S.E.2d 224 (N.C. Ct. App. 2002). “2d at 59 (quoting N.C.G.S. § 105-287(c) (2001)). We agree that a post-octennial sale of the property in question cannot be used for a valuation adjustment.”

Appeal of Philip Morris USA, 503 S.E.2d 679 (N.C. Ct. App. 1998). “" N.C. Gen.Stat. § 105-287(c) (1987). Cabarrus County's most recent reevaluation year was 1991, thus the parties stipulated that the value of the improvements to the land should be appraised at what those improvements would have been worth on 1 January 1991, rather than…”

In re the Appeal of Dickey, 431 S.E.2d 203 (N.C. Ct. App. 1993). “00 for the tax year 1989, and that, under the provisions of N.C.G.S. § 105-287, the Assessor was authorized to reappraise the house in 1990, but that such reappraisal is effective as of 1 January of the year in which it is made and is not retroactive.”

In re Appeal of Corbett, 530 S.E.2d 90 (N.C. Ct. App. 2000).

— N.C. Gen. Stat. § 105-287(d) — 1 case

Thrash v. City of Asheville, 393 S.E.2d 842 (N.C. 1990). “” N.C.G.S. § 105-287(b)(4) (1985). See also N.”

— N.C. Gen. Stat. § 105-287(g)(2) — 2 cases

In re: Lowe's Home Ctrs. (N.C. Ct. App. 2020).

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