101 North Broadway Associates v. Board of Assessors

168 Misc. 2d 74, 635 N.Y.S.2d 1012, 1995 N.Y. Misc. LEXIS 602
CourtNew York Supreme Court
DecidedNovember 28, 1995
StatusPublished

This text of 168 Misc. 2d 74 (101 North Broadway Associates v. Board of Assessors) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
101 North Broadway Associates v. Board of Assessors, 168 Misc. 2d 74, 635 N.Y.S.2d 1012, 1995 N.Y. Misc. LEXIS 602 (N.Y. Super. Ct. 1995).

Opinion

OPINION OF THE COURT

Mary M. Werner, J.

This is an RPTL article 7 proceeding to review the real property tax assessment of certain real property located on West Main Street, River head, New York. A trial was held before this court on October 23, 1995. Submissions were received on November 8, 1995. The following constitutes the court’s findings of facts and conclusions of law.

The subject property consists of 5.2 acres improved with seven two-story garden apartment buildings containing 112 apartment units. There is also a parking garage building containing 16 parking stalls. The property is located on the north side of West Main Street just east of the Long Island Expressway.

After petitioner’s previous tax certiorari proceedings were settled in 1993, the Board of Assessors immediately raised the assessment on the subject property, resulting in the instant petition. The proceeding is limited to the 1994-1995 tax year.

At the trial both parties stipulated to the equalization rate, which is .3247. Both sides also agreed that the income approach to value was the most appropriate method of appraising the subject income-producing property. Both parties’ experts used this method which involves first a determination of the net annual income for the subject property. This is done by subtracting gross annual expenses from gross annual income. To this figure a capitalization rate is applied as determined by each appraiser. The result is the appraiser’s opinion of the present worth of the future benefits of the property, or its present fair market value.

In this case, both experts were in close agreement on both the expenses of the apartment complex and the capitalization [76]*76rate. It is the income of the property which presents the biggest dispute.

It is well settled that actual income and expenses, when available, are the best indicators of an income-producing property’s value (see, 41 Kew Gardens Rd. Assocs. v Tyburski, 70 NY2d 325 [1987]; Matter of Town of Riverhead v Saffals Assocs., 145 AD2d 423 [2d Dept 1988]).

"Actual rental income is usually the best guide to value unless the rent has been determined without regard to the market place.” (Matter of Burke Apts. v Howe, 98 AD2d 595 [3d Dept 1984].)

Petitioner’s appraiser analyzed eight comparable rental properties and established a range of market rents per month. He concluded that the actual rental of $645 for a one bedroom with a deck, $630 for a one bedroom without a deck and $810 for a two bedroom with a deck were within the market range and therefore the actual rental was the indicated rental.

Petitioner’s contention as to potential gross income (P.G.I.) can be summarized:

Units Rent/mo 12 P.G.I.
1 Bedroom w/deck 28 X $645 X 12 = $216,720
1 Bedroom w/o deck 56 X 630 X 12 = 423,360
2 Bedroom 27 X 810 X 12 = 262,440
$902,520

Respondent’s appraiser, without benefit of the rent roll, analyzed four comparable rental units and determined that the range of market rent for a comparable one bedroom was $650 to $730 and selected $675 as the indicated rent for a one bedroom in the subject property. Similarly, with respect to two-bedroom apartments, the appraiser found that the range of market rents to be $775-$860 and found that the indicated rent for petitioner’s two-bedroom apartments to be $850.

Respondent’s contention as to potential gross income is summarized:

Units Rent/mo 12 P.G.I. | 1
1 Bedroom CO X $675 cq X = $680,400
2 Bedroom X OO <N 850 X 12 285,600
1966,000

$966,000 minus $902,520 = $63,480. Thus, respondents attribute to value more than $60,000 in income than petitioners actually received.

[77]*77Respondents’ appraiser provides no explanation for not accepting petitioner’s actual rent except for her assertion that she never received the rent roll. (As evidenced by petitioner’s exhibit 4, petitioner’s counsel forwarded this information to respondent on June 2, 1994. Apparently, it never made its way to respondent’s appraiser.) She did testify, however, that even if she had the rent roll, her appraisal would remain the same. She testified that her figures are based on the market, but provides no plausible reason to reject petitioner’s actual rent.

Moreover, Matter of Merrick Holding Corp. v Board of Assessors (45 NY2d 538 [1978]), cited by respondents’ counsel in conference, provides no support for this rejection.

In that case, the Court of Appeals rejected a per se rule and stated that "if examination discloses that rent has been arbitrarily set without regard to the market rental value whether through self-dealing * * * or, certainly where there is any indication of collusion, the rent arrangement will be of little, if any guidance to sound appraisal” (supra, at 543).

In the case at bar, respondent has not attempted to show self-dealing or collusion.

Moreover, this is not a case where value is distorted because of reliance on contract rents involving property subject to below market long-term leases which would require compensatory measures (supra).

Since respondent failed to give any reason for rejecting the actual rent, the court adopts petitioner’s expert’s figures with respect to rental income, to wit, $902,520.

The court also accepts petitioner’s figures with respect to additional income ($9,600 for parking and $9,600 for laundry) as well as the amount of deduction for vacancy and collection, $27,363. The court notes that these figures are consistent with or very similar to respondents’ figures.

The effective gross income (e.g.i.) is thus:

$ 902,520.00 (apt. rent)
+
+
9.600.00
9.600.00 ■ 27,363.60
$ 894,356.40
(laundry)
(parking)
(vacancy & collection) (e.g.i.)

There was very little discrepancy between petitioner’s total expenses of $402,069 and respondents’ of $392,708.52. Again, respondents provided no reason not to accept petitioner’s figures which are based in large part on actual figures. Accordingly, the court accepts petitioner’s figures as to expenses:

[78]*78$ 894,356.40
- 402,069.38
$ 492,287.02 (net operating income before deduction of taxes)

The court must now apply the capitalization rate to the net income. Petitioner’s appraiser sets forth 0.1333 as the appropriate rate, while respondent’s appraiser sets forth 0.1340.

The court accepts petitioner’s rate of 0.1333.

492,287.02 = 3,693,075.92
0.1333

Thus, the indicated value is $3,693,075.92. To determine the indicated assessment one must multiply the indicated value by the equalization rate of .3247:

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Related

41 Kew Gardens Road Associates v. Tyburski
514 N.E.2d 1114 (New York Court of Appeals, 1987)
Merrick Holding Corp. v. Board of Assessors
382 N.E.2d 1341 (New York Court of Appeals, 1978)
John P. Burke Apartments, Inc. v. Howe
98 A.D.2d 595 (Appellate Division of the Supreme Court of New York, 1984)
Town of Riverhead v. Saffals Associates, Inc.
145 A.D.2d 423 (Appellate Division of the Supreme Court of New York, 1988)

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168 Misc. 2d 74, 635 N.Y.S.2d 1012, 1995 N.Y. Misc. LEXIS 602, Counsel Stack Legal Research, https://law.counselstack.com/opinion/101-north-broadway-associates-v-board-of-assessors-nysupct-1995.