Central Nursing Realty, LLC v. Illinois Property Tax Appeal Board

2020 IL App (1st) 180994
CourtAppellate Court of Illinois
DecidedJune 11, 2020
Docket1-18-0994
StatusPublished
Cited by7 cases

This text of 2020 IL App (1st) 180994 (Central Nursing Realty, LLC v. Illinois Property Tax Appeal Board) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Central Nursing Realty, LLC v. Illinois Property Tax Appeal Board, 2020 IL App (1st) 180994 (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 180994 No. 1-18-0994 Opinion filed June 11, 2020 Fourth Division ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

CENTRAL NURSING REALTY, LLC, ) Petition for Review of a Final ) Administrative Decision of the Petitioner, ) Illinois Property Tax Appeal Board ) v. ) ) THE ILLINOIS PROPERTY TAX APPEAL ) BOARD; THE COOK COUNTY BOARD OF ) REVIEW; and THE CHICAGO BOARD OF ) EDUCATION, ) ) Nos. 11-31329.001-C-3 through 11- Respondents. ) 31329.010-C-3

JUSTICE LAMPKIN delivered the judgment of the court, with opinion. Justice Burke concurred in the judgment and opinion. Presiding Justice Gordon specially concurred.

OPINION

¶1 Central Nursing Realty, LLC (Central Nursing), challenges a decision of the Illinois

Property Tax Appeal Board (Board) assessing the value of its real property. Central Nursing argues

that the Board overstated the fair market value of the property and failed to consider its argument No. 1-18-0994

and supporting evidence that the property was inequitably assessed in comparison to similar

properties. For the following reasons, we affirm the Board’s decision. 1

¶2 I. BACKGROUND

¶3 The subject property is a 245-bed, skilled-care nursing home located at 2450 North Central

Avenue in Chicago, Illinois, in the Jefferson Township section of Cook County. It consists of

32,334 square feet of land, improved with a four-story, 65,088 square foot building with 52,157

square feet above grade. The building was constructed in 1973 of masonry and steel. Additional

site improvements include a 45-car paved parking lot. Central Nursing purchased the nursing home

business as a going concern, including its real property and tangible and intangible personal

property, for $25 million in 2009. At the time, the buyer and seller attributed approximately $7.5

million of the total purchase price to the value of the real estate.

¶4 In 2011, the Cook County Assessor assessed the land at a value of $127,312 and the

improvements at a value of $1,930,042, for a total assessed value of $2,057,354. Because

commercial property in Cook County is assessed at 25% of its fair market value, the assessment

implied that the subject property had a fair market value of $8,229,416. Central Nursing appealed

to the Cook County Board of Review, which rejected its request to reduce the assessment.

¶5 Central Nursing then appealed to the Board, arguing that the assessment was excessive and

inequitable and that it should be reduced to one of several alternative amounts. First, Central

Nursing argued that the assessment should be reduced to $1,872,875. In support, Central Nursing

submitted the real estate transfer declaration form filed after its 2009 purchase of the going

concern, in which the parties attested that the fair market value of the real estate was $7,491,500.

1 In adherence with the requirements of Illinois Supreme Court Rule 352(a) (eff. July 1, 2018), this appeal has been resolved without oral argument upon the entry of a separate written order.

-2- No. 1-18-0994

¶6 Next, under what it called the “Economic Approach to Value,” Central Nursing argued that

the assessment should be reduced to $1,816,666 to reflect a fair market value of $7,266,664. In

support of this argument, Central Nursing attached a 2010 financial statement showing revenue of

$10,222,798. Although the statement showed net income of $1,236,368, Central Nursing instead

(without explanation) “[s]tabiliz[ed]” its expenses at 90% of revenue, producing a 2010 net income

of $1,022,280, which it then “capitaliz[ed]” at a rate of 14.07%, yielding (according to its

calculation) a fair market value of $7,266,664. 2

¶7 As a further alternative, Central Nursing argued that the assessment should be reduced to

$1,087,496, based on a fair market value of $4,349,987, which it calculated using the capital

component of the Medicaid reimbursement rate that it deemed attributable to the real estate. As

support for this method of valuation, Central Nursing cited (but did not attach) an unpublished,

out-of-state trial court decision.

¶8 As its next alternative, Central Nursing argued that the assessment should be reduced to

$1.35 million based on an appraised fair market value of $5.4 million. In support, Central Nursing

submitted an appraisal report by certified real estate appraiser Ryan Korth, which analyzed the

property using three approaches to valuation—the cost approach, the income capitalization

approach, and the sales comparison approach. Under the cost approach, Korth estimated the value

of the land by considering sales of four comparable parcels in surrounding neighborhoods between

2008 and 2011. After calculating the sales prices of those lots per square foot of floor area ratio

(which measures the maximum allowable ratio of building area to lot size) and making relevant

adjustments, Korth concluded that the subject property’s land had a fair market value of $1 million.

2 As the Board later noted, a correct calculation using Central Nursing’s figures yields a fair market value of $7,265,672.

-3- No. 1-18-0994

¶9 Korth then used the Marshall Valuation Service (MVS) cost manual to estimate the cost of

reproducing the building. Based on the type and quality of its construction, Korth classified the

building as a Class C—Average Convalescent Hospital with a replacement cost of $11,484,825.

Korth explained that he did not factor entrepreneurial incentive (the profit that a developer can

expect to earn on a project) into the building’s replacement cost because nursing homes are not

typically built by developers on speculation. Korth then calculated the building’s depreciated value

using the age/life method. Based on its condition and maintenance history, Korth estimated that

the building had an effective age of 25 years. In addition, relying on the MVS cost manual’s

estimate for Class C—Average Convalescent Hospitals, Korth determined that the building had a

total economic life of 40 years. By dividing the building’s effective age by its total economic life,

Korth calculated that the building had depreciated by 62.5% and had a current fair market value

of $4,300,184. Finally, Korth estimated that the property’s site improvements had a depreciated

value of $40,000. In total, under the cost approach, Korth concluded that the property’s fair market

value was $5.3 million, rounded.

¶ 10 Under the income capitalization approach, Korth determined that the total value of the

business as a going concern was $25.2 million. He arrived at this figure by dividing the business’s

adjusted net operating income by a loaded capitalization rate. He then subtracted the value of the

real estate (as previously determined under the cost approach) from the going concern value,

yielding a non-real-estate business value of $19.9 million. In a process that the Board described as

“somewhat circular,” Korth then subtracted the business’s non-real-estate value from its going

concern value, which (unsurprisingly) yielded a real estate value of $5.3 million.

¶ 11 Under the sales comparison approach, Korth considered recent sales of four comparable

nursing home businesses. After subtracting the businesses’ non-real-estate values and making

-4- No. 1-18-0994

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Central Nursing Realty, LLC v. Illinois Property Tax Appeal Board
2020 IL App (1st) 180994 (Appellate Court of Illinois, 2020)

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2020 IL App (1st) 180994, Counsel Stack Legal Research, https://law.counselstack.com/opinion/central-nursing-realty-llc-v-illinois-property-tax-appeal-board-illappct-2020.