962 River Avenue, LLC v. Township of Lakewood

CourtNew Jersey Tax Court
DecidedNovember 9, 2017
Docket004744-2013
StatusUnpublished

This text of 962 River Avenue, LLC v. Township of Lakewood (962 River Avenue, LLC v. Township of Lakewood) 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
962 River Avenue, LLC v. Township of Lakewood, (N.J. Super. Ct. 2017).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

TAX COURT OF NEW JERSEY

Patrick DeAlmeida R.J. Hughes Justice Complex Presiding Judge P.O. Box 975 25 Market Street Trenton, New Jersey 08625-0975 (609) 815-2922 x54620

November 8, 2017

Salvatore Alfieri, Esq. Cleary, Giacobbe, Alfieri, Jacobs, LLC Lakeview Professional Building 5 Ravine Drive Matawan, New Jersey 07747

Eileen W. Toll, Esq. Schneck Law Group, LLC 301 Livingston Avenue, Suite 105 Livingston, New Jersey 07039

Re: 962 River Avenue, LLC v. Township of Lakewood Docket No. 004744-2013

Dear Counsel:

This letter constitutes the court’s opinion after trial in the above-referenced matter

challenging an assessment on real property for tax year 2013. The central question before the court

is which of two approaches to value – the income capitalization approach, or the cost approach –

will provide the most credible evidence of the true market value of the subject property, a skilled

nursing and rehabilitation facility. For the reasons stated more fully below, the court concludes that the cost approach is the more credible way to determine the property’s true market value. As

a result of this conclusion, the court adopts the opinion of true market value offered by the

township’s expert and affirms the assessment for tax year 2013.

I. Procedural History and Findings of Fact

The following findings of fact and conclusions of law are based on the evidence and

testimony admitted at trial.

Plaintiff 962 River Avenue, LLC, is the owner of real property in defendant Lakewood

Township. The parcel, designated in the records of the municipality as Block 430, Lot 64, and

commonly known as 962 River Avenue, is approximately 5.65 acres on which sits a 126-unit, 242-

bed, skilled nursing facility that provides short-term rehabilitation services, long-term care, and

specialty services for Huntington Disease. The building is approximately 81,500 square feet with

a 16,272 square-foot basement.1 Originally constructed in 1983, the structure has undergone

extensive renovations, including the construction of an addition, completed in 2008. The building

is primarily concrete block with stucco finish and has two stories with two elevators.

Approximately 90% of the income at the facility is derived from residents receiving

Medicaid assistance. The remaining 10% of income is obtained from of private sources and

Medicare. Patients at the subject property, as is generally the case at nursing and rehabilitation

facilities, pay for both care and lodging. Undoubtedly, the larger share of patient fees are for

nursing and personal care, but it cannot be disputed that a portion of the fees are for a tenancy in

real property. See Rolling Hills of Hunterdon, L.P. v. Township of Clinton, 15 N.J. Tax 364, 367-

1 The parties offered conflicting testimony with respect to the size of the building. Plaintiff’s expert testified that the building is approximately 75,000 square feet. The court finds credible the testimony of defendant’s expert that the building is 81,500 square feet in size.

2 68 (Tax 1995)(holding that nursing home is income-producing property for purposes of N.J.S.A.

54:4-34).

For the tax year 2013, the subject property was assessed as follows:

Land $ 2,260,000 Improvement $ 8,870,300 Total $11,130,300

The Chapter 123 average ratio for the municipality for tax year 2013 is 85.94%. When the average

ratio is applied to the assessment, the implied equalized value of this parcel for tax year 2013 is

$12,951,200 ($11,130,300 ÷ .8594 = $12,951,245).

On April 1, 2013, plaintiff filed a Complaint challenging the tax year 2013 assessment.

During the trial, each party presented an expert real estate appraiser who offered an opinion

of the true market value of the subject property on October 1, 2012, the relevant valuation date.

There is no dispute that the witnesses were qualified to offer their expert opinions, summarized as

follows:

Plaintiff’s Expert $ 7,338,787 Defendant’s Expert $13,469,000

Although the experts agreed that the highest and best use of the subject property was its

continued use as a nursing and rehabilitation facility, they offered conflicting opinions with respect

to which approach to determining true market value is appropriate for the subject. Plaintiff’s expert

offered an opinion of value based only on the income capitalization approach. Defendant’s expert

offered an opinion of value based only on the cost approach. Each expert considered, and

ultimately rejected, other approaches to determining value.

3 II. Conclusions of Law

The court’s analysis begins with the well-established principle that “[o]riginal assessments

. . . are entitled to a presumption of validity.” MSGW Real Estate Fund, LLC v. Borough of

Mountain Lakes, 18 N.J. Tax 364, 373 (Tax 1998). As Judge Kuskin explained, our Supreme

Court has defined the parameters of the presumption as follows:

The presumption attaches to the quantum of the tax assessment. Based on this presumption the appealing taxpayer has the burden of proving that the assessment is erroneous. The presumption in favor of the taxing authority can be rebutted only by cogent evidence, a proposition that has long been settled. The strength of the presumption is exemplified by the nature of the evidence that is required to overcome it. That evidence must be “definite, positive and certain in quality and quantity to overcome the presumption.”

[Ibid. (quoting Pantasote Co. v. City of Passaic, 100 N.J. 408, 413 (1985)(citations omitted)).]

The presumption of correctness arises from the view “that in tax matters it is to be presumed

that governmental authority has been exercised correctly and in accordance with law.” Pantasote,

supra, 100 N.J. at 413 (citing Powder Mill I Assocs. v. Township of Hamilton, 3 N.J. Tax 439 (Tax

1981)); see also Byram Twp. v. Western World, Inc., 111 N.J. 222 (1988). The presumption

remains “in place even if the municipality utilized a flawed valuation methodology, so long as the

quantum of the assessment is not so far removed from the true value of the property or the method

of assessment itself is so patently defective as to justify removal of the presumption of validity.”

Transcontinental Gas Pipe Line Corp. v. Township of Bernards, 111 N.J. 507, 517 (1988).

“The presumption of correctness . . . stands, until sufficient competent evidence to the

contrary is adduced.” Little Egg Harbor Twp. v. Bonsangue, 316 N.J. Super. 271, 285-86 (App.

Div. 1998)(citation omitted); Atlantic City v. Ace Gaming, LLC, 23 N.J. Tax 70, 98 (Tax 2006).

“In the absence of a R. 4:37-2(b) motion . . . the presumption of validity remains in the case through

4 the close of all proofs.” MSGW Real Estate Fund, LLC, supra, 18 N.J. Tax at 377. In making the

determination of whether the presumption has been overcome, the court should weigh and analyze

the evidence “as if a motion for judgment at the close of all the evidence had been made pursuant

to R. 4:40-1 (whether or not the defendant or plaintiff actually so moves), employing the

evidentiary standard applicable to such a motion.” Ibid. The court must accept as true the proofs

of the party challenging the assessment and accord that party all legitimate favorable inferences

from that evidence. Id. at 376 (citing Brill v. Guardian Life Ins. Co. of Am., 142 N.J. 520, 535

(1995)).

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