Constructing Public Rent: Property Tax Appeals and the Fiscal Strategies of Rentier Capitalism (McCanless, 2025)

Summary

"Constructing public rent: Property tax appeals and the fiscal strategies of rentier capitalism," by Michael McCanless, appeared in Geoforum 160 (2025). It examines an assessment-process channel the wiki's mass appraisal and tax capitalization pages don't currently cover: the property tax appeal itself as a site of value extraction, using a novel dataset linking Memphis, Tennessee property ownership records to appeal filings, 2021–2023.

The Finding

The paper finds a sharp, ownership-type-graded pattern in who appeals their property-tax assessment: institutional single-family-rental investors file appeals at nearly three times the rate of other single-family investors (12.5% vs. 4.3%), and roughly six times the rate of homeowners (12.5% vs. 2.2%). McCanless frames this not as isolated tax-minimization behavior but as a systematic "fiscal strategy" — large, well-resourced institutional landlords treat contesting assessments as a routine part of extracting value from the city's fiscal apparatus, shifting the tax burden away from themselves and, mechanically, onto owners (disproportionately homeowners) who do not appeal at anything close to the same rate.

Relation to the Georgist Case

This complicates a clean version of the wiki's assessment feasibility case in a specific, practically important way: even where a jurisdiction has serviceable assessment methodology, the appeals process itself can become an unequal-access channel through which sophisticated, well-resourced owners systematically lower their effective tax burden relative to smaller owners who lack the same capacity to contest. It is a companion concern to corporate asset-stripping and the wiki's tax capitalization coverage: even a formally well-designed land or property tax is only as equitable as its administrative and appeals infrastructure, a design consideration LVT proposals need to account for explicitly rather than assume away.

Nuances and Limits

• A single US city, three-year window. Memphis's institutional single-family-rental market is unusually large and well-documented, which is part of why it makes a good case study, but the specific magnitudes may not generalize to jurisdictions with different landlord concentration or appeals procedures.
• Property tax generally, not LVT specifically. The paper studies conventional (land-plus-improvement) property tax appeals; the mechanism (unequal capacity to contest assessments) would apply to a land-only tax roll as well, but this page does not claim the paper studied that case.
• Abstract-level source (B-claim). The publisher page was blocked to this session; this page is built from a well-corroborated WebSearch reconstruction of the paper's key finding and framing, not a full read of its methodology or discussion sections.

Bears On

• Concept: Mass Appraisal Methods — a caution that assessment accuracy alone doesn't guarantee equitable outcomes if appeals access is unequal.
• Concept: Tax Capitalization — the appeals channel is a mechanism by which nominally uniform assessment can still produce unequal effective burdens.
• Concept: Asset-Stripping — a related channel by which sophisticated capital extracts value that smaller owners cannot access.

See Also

• Mass Appraisal Methods
• Tax Capitalization
• Objection: Land Value Can't Be Assessed Accurately
• Rentier
• Holz, Perez-Truglia, Simon & Zentner: AI and Property Tax Appeals — the demand-side companion: even a free, AI-assisted appeals tool can widen the same access disparities this paper documents on the supply side

Sources

1. Michael McCanless (2025), "Constructing public rent: Property tax appeals and the fiscal strategies of rentier capitalism," Geoforum 160: 104232, DOI 10.1016/j.geoforum.2025.104232. ScienceDirect — fetch blocked (403) to this session 2026-08-30; Crossref and Semantic Scholar carried no deposited abstract text; summary reconstructed from a WebSearch/ResearchGate listing reproducing the paper's key finding verbatim ("institutional single-family rental investors (12.5%) are nearly three times as likely to file property tax appeals when compared to other single-family investors (4.3%) and six times as likely when compared to homeowners (2.2%)") — used for the Memphis 2021-2023 dataset and the "fiscal strategy" framing (B-claim; secondary description of the paper's own reported figures, not a full read of the methodology or discussion).