Robert McNergney wants to live in Albemarle County, Va., where schools are good, tax rates are low and the level of services high. He also wants to stay in his home of 16 years, inside the boundaries of Charlottesville.

Thanks to a quirky, seven-year-old Virginia law, he may be able to do both.

McNergney and a small band of citizens who live in Charlottesville want their city to become a town. No more independence. No more "City Limits" signs. Just another part of sprawling Albemarle County, about 120 miles southwest of Washington.

Residents are circulating petitions and say they have collected 1,700 of the 2,750 signatures they need to start the legal process, called reversion. If they succeed, the City of Charlottesville would cease to exist.

It would be the second Virginia city to revert to a town, the first being the small city of South Boston five months ago.

Since South Boston's reversion, a few other small cities in Virginia have considered the change or are in the process of doing so. Those include Fredericksburg and Winchester close to the Northern Virginia suburbs, as well as Petersburg and Martinsville. The possibility has terrified county officials near those cities, who fear the counties would have to assume added financial burdens when a city becomes a town.

Moving to town status has certain advantages for cities, which are prohibited from annexing land to expand their tax bases and find it increasingly difficult to finance all the services required by residents.

"The handwriting is on the wall," McNergney said. "Taxes are much higher in the city than the county. There are a lot of indications that eventually we are not going to be able to afford the social services that we provide."

Albemarle County Executive Robert W. Tucker Jr. said the county Board of Supervisors is opposed to Charlottesville's reversion and has set up committees to study the fiscal impact if it happens.

"We would be looking at about a $3 million deficit," Tucker said. "We'd have to pick up social services, their courts, education. We'd have to make it up by reducing expenditures on our side or by a rate increase for our taxpayers."

McNergney's group is seeking a status that is common in every other state in the nation, where residents of cities and towns also are residents of counties. But in Virginia, cities are independent of the counties in which they sit. Residents of Virginia cities pay their own taxes and elect their own leaders, but don't vote in county elections or benefit from county services.

Many of Virginia's independent cities were set up 40 or 50 years ago, when residents of burgeoning towns began clamoring for more services and better schools than the then-rural counties were willing to provide.

That's what happened in the city of Falls Church, which incorporated in the late 1940s primarily for the purpose of starting a new school system.

"We have the personalized approach to education," says Merni Fitzgerald, vice mayor of the 2.2-square-mile city of 9,600. "The school system is small enough that teachers know their students. People have the opportunity to become involved."

Fitzgerald says Falls Church is "fiercely independent" and has never considered reverting to its one-time town status. The same goes for Fairfax City, which pays Fairfax County to run its schools, and Manassas, which has been in a 20-year-feud with Prince William County and probably would never agree to become subsidiary.

But many aging cities across the state are finding it financially difficult to go it on their own.

"If you don't have an expanding tax base, you are locked in financially," said Ed Daley, the city manager of Winchester, which has begun to look at the possibility of reversion. "Therefore, town status has a much greater significance."

Spotsylvania County Administrator Kimball Payne finds reversion "almost scary in its simplicity," mostly because, he said, "There is no referendum required {for a town to revert} and that's a concern."

In fact, under the reversion procedure, a special three-judge panel appointed by the Virginia Supreme Court decides whether to approve the change.

The process can be started by a city council or, as in Charlottesville, by a petition of 15 percent of the registered voters.

The Virginia Commission on Local Government reviews the reversion application and makes a recommendation to the court. In the South Boston case, the only case, so far, county officials tried to impose conditions on the new town, but the court rejected them all.

The reversion law, which went into effect in 1988, transfers management of all social services, the courts and education to the county, which would also have to bear the costs of those programs -- a reality that would almost certainly mean higher taxes for county residents.

And that is just what has county officials throughout the state worried.

"A city could incur major capital improvements, maybe some schools or a water system, and then revert. Those debts become an obligation of the entire county," said James D. Campbell, the executive director of the Virginia Association of Counties.

A city that has become a town could still impose its own taxes and provide some limited services, but most major functions would be transferred to the county. Virginia's towns also have an easier time annexing land because development gets taxed by the county even if it sits within town limits.

At last week's annual Virginia Association of Counties meeting, county officials and politicians held an informal strategy session to discuss how to deal with the fiscal implications if their nearby cities became towns.

One of those at the meeting was Payne, of Spotsylvania, which borders Fredericksburg. In the last three months, the city has studied the possibility of becoming a town.

"An unanswered issue is whether a city could revert to a town, annex land and then revert back to a city," Payne said, noting that the Spotsylvania shopping mall sits on the border of the city and the county. "Clearing up that question alone would make a lot of people feel a whole lot better."