BASF Wyandotte Corp v. Twp. South Brunswick / Twp of South Brunswick v. BASF Wyandotte Corp.

CourtNew Jersey Tax Court
DecidedFebruary 6, 2020
Docket002985-1997, 000624-1998, 001050-1999, 000235-2000
StatusUnpublished

This text of BASF Wyandotte Corp v. Twp. South Brunswick / Twp of South Brunswick v. BASF Wyandotte Corp. (BASF Wyandotte Corp v. Twp. South Brunswick / Twp of South Brunswick v. BASF Wyandotte Corp.) 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
BASF Wyandotte Corp v. Twp. South Brunswick / Twp of South Brunswick v. BASF Wyandotte Corp., (N.J. Super. Ct. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

___________________________________ BASF WYANDOTTE CORPORATION, ) TAX COURT OF NEW JERSEY ) DOCKET NO. 002985-1997 Plaintiff-Counterclaim ) DOCKET NO. 000624-1998 Defendant, ) ) v. ) ) TOWNSHIP OF SOUTH BRUNSWICK, ) ) Defendant-Counterclaim ) Plaintiff. ) ___________________________________ ) TOWNSHIP OF SOUTH BRUNSWICK, ) TAX COURT OF NEW JERSEY ) DOCKET NO. 001050-1999 Plaintiff, ) DOCKET NO. 000235-2000 ) v. ) ) OPINION BASF WYANDOTTE CORPORATION, ) ) Defendant. ) ___________________________________ )

Decided: February 4, 2020

Harry Haushalter, Esq., for counterclaim-plaintiff/plaintiff Township of South Brunswick

Seth I. Davenport, Esq., for counterclaim-defendant/defendant BASF Wyandotte Corporation

DeALMEIDA, J.T.C. (t/a)

This is the court’s opinion after trial in the above-referenced matters. At issue is the

valuation for local property tax purposes of real property on which was located a chemical

processing plant. The municipality claims the assessments on the property for tax years 1997

through 2000 are erroneous because they do not include the true market value of certain machinery and equipment on the property that must be treated as real property for purposes of

local taxation pursuant to N.J.S.A. 54:4-1. For the reasons stated more fully below, the

assessments for each tax year are affirmed.

I. Findings of Fact

During the years in question, BASF Wyandotte Corporation (“BASF”) owned a parcel of

land in South Brunswick Township. The property is 34.728 acres designated by the township as

Block 15.03, Lot 51 and commonly known as 1059-1063 Cranbury-South River Road. On the

relevant valuation dates, the property was operated as a chemical processing plant with numerous

buildings aggregating approximately 250,000 square feet, as well as additional site facilities,

tanks, foundations, paving, an unused wastewater treatment facility, and other improvements.

The plant included styrene and pentane unloading facilities, twenty-four chemical reactors, two

product-drying complexes, a cooling tower, a central packing complex, and associated wiring

and piping. These features, which are comprised of ninety-seven pieces of machinery and

equipment which will be discussed in greater detail below, were used to produce expandable

polystyrene (EPS) beads, then the most widely used foam insulating material in the construction

industry.

For tax years 1997, 1998, 1999, and 2000, the property was assessed as follows:

Land $ 2,778,200 Improvement $12,858,900 Total $15,637,100

The Chapter 123 average ratio for South Brunswick Township for tax year 1997 is

102.56%. When the average ratio is applied to the assessment, the implied equalized value of

the subject property for that tax year is $15,246,782 ($15,637,100 ÷ 1.0256 = $15,246,782).

2 The Chapter 123 average ratio for South Brunswick Township for tax year 1998 is

104.77%. When the average ratio is applied to the assessment, the implied equalized value of

the subject property for that tax year is $14,925,169 ($15,637,100 ÷ 1.0477 = $14,925,169).

The Chapter 123 average ratio for South Brunswick Township for tax year 1999 is

102.96%. When the average ratio is applied to the assessment, the implied equalized value of

the subject property for that tax year is $15,187,548 ($15,637,100 ÷ 1.0296 = $15,187,548).

The Chapter 123 average ratio for South Brunswick Township for tax year 2000 is

102.94%. When the average ratio is applied to the assessment, the implied equalized value of

the subject property for that tax year is $15,190,499 ($15,637,100 ÷ 1.0294 = $15,190,499).

It is undisputed the assessments do not include the true market value of any machinery

and equipment at the subject property. BASF filed complaints seeking a reduction in the

assessments for tax years 1997 and 1998. South Brunswick filed counterclaims seeking to

increase the assessments for those tax years. The municipality thereafter filed complaints

seeking to increase the assessments for tax years 1999 and 2000. No counterclaims were filed by

the taxpayer for those years. Prior to trial, the taxpayer withdrew its complaints, leaving South

Brunswick as the only party challenging the assessments for the tax years at issue.

The matters were tried over twenty-one days. 1 Post-trial briefing identified the following

unresolved issues:

1. Which, if any, machinery and equipment at the subject property is real property subject to local property tax pursuant to N.J.S.A. 54:4-1?

1 At the conclusion of trial, the court reserved decision. The judge who tried the matters subsequently retired without issuing an opinion. The taxpayer thereafter moved for a mistrial and requested the matters be tried before another judge of this court. The township opposed that motion. The court denied the taxpayer's motion and the matter was assigned to the author of this opinion for decision based on the trial record.

3 2. The parties stipulated to the true market value of the machinery and equipment at the subject property, in the event the court determines any of it is subject to local property tax. However, with respect to some of the machinery and equipment, the parties stipulated to two values: the value installed (including transportation and installation costs) and the value uninstalled. The court must determine which of the two values should be included in the assessments.

3. The parties' stipulation with respect to the true market value of the machinery and equipment reflects the physical depreciation of the machinery and equipment. The court must determine whether functional obsolescence and external obsolescence must also be considered and, if so, must determine the effect those forms of obsolescence have on the value of the machinery and equipment.

4. With respect to valuing the remainder of the subject property, the parties reached a number of stipulations: (a) the highest and best use of the subject property is the use in place on the valuation dates; (b) the cost approach is the exclusive approach to valuing the subject property; and (c) the true market value of the land. The court, however, must determine the true market value of the improvements at the subject property.

5. Finally, the court must determine whether entrepreneurial profit must be included when determining the value of the subject property under the cost approach. If so, the court must determine the effect of entrepreneurial profit on the subject property's true market value.

The issues are addressed in turn below.

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 defined the parameters of the presumption as follows:

[t]he 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

4 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.

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BASF Wyandotte Corp v. Twp. South Brunswick / Twp of South Brunswick v. BASF Wyandotte Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/basf-wyandotte-corp-v-twp-south-brunswick-twp-of-south-brunswick-v-njtaxct-2020.