ACO Realty Corp. v. Srogi

127 Misc. 2d 899, 487 N.Y.S.2d 912, 1984 N.Y. Misc. LEXIS 3766
CourtNew York Supreme Court
DecidedDecember 10, 1984
StatusPublished

This text of 127 Misc. 2d 899 (ACO Realty Corp. v. Srogi) 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
ACO Realty Corp. v. Srogi, 127 Misc. 2d 899, 487 N.Y.S.2d 912, 1984 N.Y. Misc. LEXIS 3766 (N.Y. Super. Ct. 1984).

Opinion

OPINION OF THE COURT

John F. Lawton, J.

At issue in these proceedings is the determination of the equalization rates for the City of Syracuse to be applied for tax years 1976, 1977, 1979, 1980, 1981 and 1982.

CONTENTIONS OF THE PARTIES

Petitioners contend that the best evidence of the true equalization rate is that found by the State Board of Equalization and Assessment (SBEA). The equalization rates, as found by the SBEA, for the years in question are as follows:

1976 35.27

1977 34.04

1979 27.80

1980 25.34

1981 22.95

1982 22.93

[900]*900Respondent contends that the better method for determining the true equalization rate is to use the all sales method, as provided for under Real Property Tax Law § 720. The equalization rates, as found by experts for the respondent, for the years in question are as follows:

Weighted Unweighted

1976 37.69 36.67

1977 35.67 33.97

1979 30.61 29.01

1980 29.11 27.61

1981 29.40 26.98

1982 31.00 30.08

TRIAL

In support of their contentions, petitioners, as part of their direct case, introduced into evidence the findings of the State Board, and through expert testimony, explained the methodology employed by the State Board in arriving at its conclusions. Prior to 1979, the State Board employed two different methods of arriving at its findings, viz., sales method and random sampling of appraisals. Since 1979 the State Board has used the statistical method of random selection of appraisals exclusively, and no longer considers sales within the taxing district in arriving at its findings.

Mr. Samuel Stein, a former key employee of the State Board, testified in detail as to the various categories of property considered and their applicability to the City of Syracuse for the years in question and as to the various monetary levels within each category chosen for random sampling.

Respondent, in its case, through the testimony of realtors, Myron A. White and John E. Nicol, introduced into evidence an all sales survey of sales which occurred within the City of Syracuse during each of the years in question between July 1st of the period two years preceding and June 30th of the preceding year, e.g., for tax year 1979, only those sales which occurred between July 1, 1977 and June 30, 1978 are to be considered. Mr. White testified as to the methodology employed by himself and his staff in assembling the sales to be considered; the methodology he used in screening the sales to determine whether they were of an arm’s length nature; and the use of said raw data in arriving at an equalization rate. In the latter regard, respondent’s experts employed two methods, i.e., a weighted and unweighted method, of arriving at their proposed equalization rates. The unweighted method is the more conventional method obtained by dividing the total of the individual [901]*901sales prices by the total of the assessments for said properties. The weighted method is more of a hybrid, whereby the respondent’s experts categorized and stratified the sales in a manner similar to that employed by the SBEA.

The balance of respondent’s case was to introduce expert testimony criticizing the SBEA’s methodology as a whole and attacking some of the individual appraisals employed by the SBEA in particular. Principal among the objections raised as to the SBEA’s methodology is the fact that there is a built-in time lag; not all categories of properties are sampled; the limited number of sample appraisals employed; the possibility of human error in the appraisals; and the failure to give any consideration to current sales after 1979.

Petitioners on redirect introduced expert evidence attacking the methodology employed by the respondent’s experts in arriving at their conclusions and questioning the validity of the all sales method itself. Petitioners in this respect contend that substantial numbers of sales, as recorded by the Onondaga County Property Tax Office, were unaccounted for and were not part of the all sales average considered by the respondent’s experts. Petitioners’ experts also attacked the methods employed by the respondent’s experts in determining whether a sale was in fact arm’s length or not, both as to the qualifications of the personnel employed for such purpose, and as to their failure to record and keep adequate documentation of their findings. Expert testimony, principally by Professor Sherman Chottiner, was also received, wherein he testified as to the preferability of a random sampling method of the SBEA over the all sales method. Principal amongst his reasons in arriving at this conclusion is the failure of the all sales method to employ random probability sampling, which results in bias or error which is unmeasurable, but which far exceeds the minimal measurable error that accompanies a truly random sampling. Dr. Chottiner further criticized the all sales method for its failure to have a proper balance between the various categories of property which likewise can result in bias or error.

LAW

Much has been written with respect to the history of Real Property Tax Law § 720, and no worthwhile purpose would be served by a further recital herein (see, Guth Realty v Gingold, 41 AD2d 479, affd 34 NY2d 440 [1974]; Matter of Standard Brands v Walsh, 92 Misc 2d 903, affd 60 AD2d 605 [1977]; 860 Executive Towers v Board of Assessors, 84 Misc 2d 525, affd 53 AD2d 463, affd sub nom. Matter of Pierre Pellaton Apts. v Board of Asses[902]*902sors, 43 NY2d 769 [1977]). Suffice it to say that Real Property Tax Law § 720 as now in effect (see, Matter of Colt Indus. v Financial Administrator, 54 NY2d 533 [1982]) provides three distinct methods for arriving at an equalization rate to be used in determining a certiorari proceeding, viz., selected parcels method, State Board of Equalization and Assessment rate, and the all sales method. The selected parcels method, although the longest in tenure, has fallen into disregard and is no longer generally employed.1

A growing number of cases have been decided wherein the courts seem to first make a determination as to which of the two remaining methods is the most appropriate to the facts of the case and then adopting that rate in arriving at a final assessment (860 Executive Towers v Board of Assessors, supra; Matter of Standard Brands v Walsh, supra; Matter of Swanz v Brant, 52 AD2d 1071 [4th Dept 1976]; Stemmer v Town of Pompey, Sup Ct, Onondaga County, Feb. 29,1984; Rab Co. Riviera Ridge Apts. v Neal, Sup Ct, Broome County, decided Apr. 26, 1982). Each of the parties herein seems to have adopted this approach in that each argues that the other party’s approach is totally erroneous and, therefore, does not merit consideration. Such an approach, however, appears to be somewhat contradictory to the wording of the statute. The Legislature at the time of Real Property Tax Law § 720’s adoption was well aware of the strengths and weaknesses of each of the methods, but nevertheless determined that both methods were acceptable.

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Bluebook (online)
127 Misc. 2d 899, 487 N.Y.S.2d 912, 1984 N.Y. Misc. LEXIS 3766, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aco-realty-corp-v-srogi-nysupct-1984.