416 Route 10 Associates v. East Hanover Township

CourtNew Jersey Tax Court
DecidedJanuary 26, 2018
Docket007748-2010, 008742-2011, 008615-2012, 001169-2013, 008219-2014, 007860-2015
StatusUnpublished

This text of 416 Route 10 Associates v. East Hanover Township (416 Route 10 Associates v. East Hanover Township) is published on Counsel Stack Legal Research, covering New Jersey Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
416 Route 10 Associates v. East Hanover Township, (N.J. Super. Ct. 2018).

Opinion

TAX COURT OF NEW JERSEY

VITO L. BIANCO 77 Headquarters Plaza JUDGE 1st Floor, North Tower Morristown, NJ 07960-3964 (609) 815-2922 Ext. 54580 Fax (973) 631-6396 NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

January 23, 2018

Via eCourts

Daniel J. Pollak, Esq. Brach Eichler LLC 101 Eisenhower Parkway Roseland, New Jersey 07068

Levi J. Kool, Esq. O’Donnell McCord, P.C. 15 Mount Kemble Avenue Morristown, New Jersey 07960

RE: 416 Route 10 Associates v. East Hanover Township Docket Nos.: 007748-2010; 008742-2011; 008615-2012; 001169-2013; 008219- 2014; 007860-2015

This letter opinion constitutes the court’s determination after trial of the direct appeals filed

by the plaintiff, 416 Route 10 Associates (“Associates”), challenging the 2010, 2011, 2012, 2013,

2014, and 2015 property tax assessments1 of its property located within the defendant municipality,

East Hanover Township (“Township”), commonly known as 416 Route 10, East Hanover, Morris

County, and designated by the taxing district as Block 103, Lot 3.01 (“Subject Property”).

For the reasons set forth herein, the court reduces the tax assessments of the Subject

Property in accordance with the true values established by Associates’ for each year at issue.

1 The appeal under Docket No. 005979-2016 was withdrawn on the record at the beginning of trial. A separate judgment has been issued in that matter.

* The Subject Property is located in the Township’s B-2 (Highway Business District) zone,2

in a densely populated area of Morris County. It contains a single story commercial strip center

retail building constructed in 1979, in overall average condition. The building contains 35,497

square feet of improved area, which is partitioned into four units. The retail units contain the

following square footage: 5,280, 12,540, 12,384 and 5,293. Each retail unit is heated and cooled

by a gas fired HVAC system. The exterior walls are stucco with large glass display window and

entry doors along the south (front) side of the building. The building’s electric and plumbing

services are adequate for its current use. The units were typical in that they had large plate glass

windows with an open concept interior design and layout for retail sales with a smaller rear

storage/office area. Each unit has one or two restrooms.

There are 123 paved parking spaces located in the front of the subject building. The lot

size is approximately 4.0 acres.

For the 2010, 2011, 2012, 2013, 2014, and 2015 tax years, the Subject Property was

assessed as follows:

Land $2,000,000 Improvements $3,733,800 TOTAL $5,733,800

Both parties offered the testimony of a professional real estate appraiser who were accepted

by the court as experts without objection; each expert prepared an appraisal report that was

admitted in evidence, also without objection. Both experts concluded that based upon demand and

physical attributes of the site, the Highest and Best use of the Subject Property, as vacant, is for

2 Permitted uses include one-family dwellings; stores; shops and markets; business and professional offices; banks and financial institutions; parking lots; restaurants; mortuary or funeral homes; theaters; bowling alleys and other similar recreational facilities; automobile sales and showrooms; business uses serving highway traffic; warehouse facilities; the finishing or assembly of articles made from previously or prepared or refined materials; the preparation and fabrication of metals and metal products, chemicals and chemical products; research activities and hotels or motels.

2 retail use in accordance with the zone. Since the present improvements contribute significantly to

the overall value of the property, are maximally productive and are consistent with the highest and

best use as vacant, both experts also concluded that the highest and best use as improved is a

continuation of the present use as a retail property.

There were no other witnesses.

According to Associates’ expert, the Subject Property’s true value on the relevant valuation

dates was:

Amount Tax Year Valuation Date $5,750,000 2010 October 1, 2009 $6,030,000 2011 October 1, 2010 $6,220,000 2012 October 1, 2011 $6,310,000 2013 October 1, 2012 $6,400,000 2014 October 1, 2013 $6,490,000 2015 October 1, 2014

Each of these conclusions of value, if accepted by the court, would result in a lower

assessment of the Subject Property for each tax year at issue, as the true value to assessment ratios

for all tax years exceed the upper limits of the common range.

While the sales comparison and cost approach to value3 were considered, the Associates’

expert relied upon the income capitalization approach. The Associates’ expert identified ten

comparable leases he concluded were comparable to the Subject Property. No adjustments were

made to reflect differences between the proposed comparables and the Subject Property. 4

3 The expert concluded that the reliability and soundness of the Sales Comparison Approach is limited within the commercial retail market, as property values can be significantly influenced by their specific income streams and vacancy rates. Within the market, it is challenging to determine exact vacancy rates and whether the leased fee interest was the determining factor in overall price. Therefore, the Sales Comparison Approach is considered a less reliable value indicator. The Cost Approach was not utilized due to the age of the building and difficulties in estimating accrued depreciation. 4 At the close of Associates’ proof, motions made by the Township to dismiss the matters pursuant to R. 4:37-2(b), and to bar Associates’ expert report, were denied by the court.

3 The Township’s expert utilized the sales comparison approach and the income approach to

determine the fee simple market value of the subject property as of each dates in question. The

cost approach was considered, however, due to the age of the subject buildings, this approach was

not employed. Further, market participants would not consider this approach in valuing the subject

property.

A search of the immediate market area revealed that there are few comparable buildings of

this size and age available for sale as of the valuation dates. The Township’s expert searched for

comparables deemed to be most similar to the Subject Property as of the dates in question. All of

the comparables were of retail facilities. Adjustments were considered for time, size,

age/condition/appeal, economic characteristics and location.

In his sales comparison approach, the Township’s expert arrived at the following values:

Amount Tax Year Valuation Date $10,470,000 2010 October 1, 2009 $ 9,760,000 2011 October 1, 2010 $ 9,760,000 2012 October 1, 2011 $ 9,400,000 2013 October 1, 2012 $ 9,400,000 2014 October 1, 2013 $ 9,230,000 2015 October 1, 2014

In his income approach, the Township’s expert arrived at the following values:

Amount Tax Year Valuation Date $ 8,800,000 2010 October 1, 2009 $ 9,335,000 2011 October 1, 2010 $10,115,000 2012 October 1, 2011 $10,940,000 2013 October 1, 2012 $10,940,000 2014 October 1, 2013 $10,940,000 2015 October 1, 2014

The Township’s expert concluded that market value of the Subject Property as of the dates

in question, was as follows:

4 Amount Tax Year Valuation Date $ 9,500,000 2010 October 1, 2009 $ 9,600,000 2011 October 1, 2010 $ 9,850,000 2012 October 1, 2011 $10,000,000 2013 October 1, 2012 $10,000,000 2014 October 1, 2013 $10,000,000 2015 October 1, 2014

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