Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp.

CourtNew Jersey Tax Court
DecidedOctober 2, 2020
Docket008862-2019
StatusUnpublished

This text of Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp. (Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp.) 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
Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp., (N.J. Super. Ct. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

TAX COURT OF NEW JERSEY

120 High Street KATHI F. FIAMINGO Mount Holly, NJ 08060 JUDGE (609) 288-9500 EXT 38303

October 2, 2020

Harry A. Happ, III and Merle E. Happ 67 Woodbury Court Clarksboro, NJ 08020

Via ecourts Scott David Burns, Esq.

RE: Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp. Docket No. 008862-2019

Dear Plaintiffs and Counsel:

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

challenging the judgment of the Gloucester County Board of Taxation for the 2019 tax year on

plaintiff’s single-family residence. For the reasons stated more fully below, the court affirms the

assessment for tax year 2019 and dismisses plaintiff’s complaint.

I. Procedural History and Factual Findings

The court makes the following findings of fact and conclusions of law based on the

evidence and testimony offered at trial in this matter.

Plaintiffs Harry A. Happ, III and Merle E. Happ (“plaintiffs”) are the owners of the single-

family home located at 67 Woodbury Court, East Greenwich Township, Gloucester County, New

Jersey identified on the tax map of the Township of East Greenwich (the “Township”) as Block

* 206, Lot 10.39 (the “subject property”). As a result of a reassessment for the 2019 the subject

property was assessed as follows:

Land: $ 65,600.00

Improvements: 309,000.00

Total $ 374,600.00

Plaintiffs filed a petition of appeal with the Gloucester County Board of Taxation (the

“Board”) challenging the 2019 tax year assessment on the subject property. On April 30, 2019,

the Board entered a Memorandum of Judgment (the “Judgment”) affirming the assessment under

judgment code “2B Assessment Affirmed – Presumption of correctness not overturned.” On May

22, 2019 plaintiffs timely filed a complaint with the Tax Court contesting the Board’s judgment.

The Township filed an answer on June 12, 2019. The matter was tried on September 21, 2020.

At trial, plaintiff Harry A. Happ, III (“plaintiff”) testified that he was a licensed real estate

agent. He provided testimony intending to demonstrate that although, by plaintiff’s calculations,

the majority of homes in his development had sold for a loss over the two year period November

2016 through November 2018, the increase in the assessments in the 2019 reassessment increased

by 10% to 18%. Plaintiff further testified that the increase in the assessment of the subject

property increased 11.7% when, according to plaintiff the actual market value increase was 1% to

3%.

Plaintiff provided a spreadsheet showing the sales of every home in his development.

Highlighting all sales in the “two-year” lookback period from November 2016 through November

2018. This period was the relevant period for determining the comparable sales for the October

1, 2018 valuation date. Plaintiff testified that each of the sales made were “sold at a loss.”

Defendant objected that the characterization as to whether property was sold at a loss was

2 irrelevant to provide any support for the market value of the subject property. The court permitted

the testimony because it involved potential evidence of the fair market value of the subject

property.

Plaintiff provided a list of sales during the referenced 2-year look back period which he

referenced to demonstrate that of the thirteen sales, six of which sold at a loss. Of the sales listed,

six sales were of models similar to that of plaintiff, the “St. Andrews.” The St. Andrew sales were

as follows:

Address Date of Sale Sales price

59 Woodbury Court 10/14/16 $ 302,000 27 Brandywine Dr. 1/17/17 $ 335,000 49 Current Dr. 1/11/18 $ 399,000 37 Shute Farm Ln. 3/15/18 $ 330,000 43 Currant Dr. 5/04/18 $ 355,000 56 Brandywine Dr. 8/20/18 $ 285,000

Thereafter plaintiff provided testimony that the property located at 27 Brandywine Drive

which sold on January 17, 2017 for $335,000 was the only sale in the relevant time period which

was similar to the subject property, with the same square footage, including a loft with a bedroom

and bath, with the exception that the subject had a basement which was partially finished that 27

Brandywine does not have. Plaintiff then agreed that an adjustment should be made to reflect the

additional value for the partially finished basement. He testified that he had spoken with a realtor

and based upon his discussion with the realtor he determined that a positive adjustment of $13,000

for the partially finished basement was warranted.

He acknowledged that he had not been inside the property which he was using as a

comparable and had not spoken with any of the participants. Nonetheless he believed that property

was comparable, as adjusted.

3 Plaintiff thereafter testified that the land upon which the subject sits is partially wet lands

of approximately 500 square feet in area. He therefore deemed that an adjustment for the loss of

use due to wetlands was necessary. He determined this adjustment with reference to other

properties with the same square footage, but whose properties did not have any “loss of usage due

to wet lands.” He further determined that the tax assessment for the land only on such properties

was $65,000, $400.00 less than the assessment for the land on the subject property. He then

determined that due to the loss of use due to wetlands, an adjustment of $1,000 was appropriate

for the loss of use due to wetlands.

After reviewing the information and his proposed adjustment, he found a value of

$349,400 for the subject property. He determined this amount referencing the average assessment

for the improvements of other similar models in his development, adding back the land value, as

adjusted, and then adding his adjustment for the partially finished basement, as follows:

Average Assessment for St. Andrews Improvement only $ 271,800 Add back assessment for land, as adjusted 64,600 Add in adjustment for partially finished basement 13,000

Total value/adjustment $ 349,400

At the conclusion of plaintiff’s testimony, defendant moved to dismiss plaintiff’s

complaint for his failure to overcome the presumption of validity. The court denied the motion

finding that plaintiff had provided some evidence of value raising a debatable question as to the

validity of the assessment.

Thereafter defendant presented its assessor who presented three comparable sales upon

which the defendant relied. Adjustments were made to each of the comparable sales for lack of a

basement, partially finished, at $43,000. Adjustments were also made for gross living area, and

in one case for a fireplace ($1,500) and patio ($3,000). The assessor provided no testimony as to

4 the manner in which any of the adjustments were made. After adjustment, the assessor testified

that the three comparable sales were $398,000, $410,500 and $337,500. The subject property was

assessed at $374,600.

II. Conclusions of Law

a. Presumption of Validity

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

and judgments of county boards of taxation 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). The

presumption “attaches to the quantum of the tax assessment. Based on this presumption, the

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Harry A. Happ, III and Merle E. Happ v. East Greenwich Twp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/harry-a-happ-iii-and-merle-e-happ-v-east-greenwich-twp-njtaxct-2020.