Joliet Township High School District 204 v. Illinois Property Tax Appeal Board Joliet Township High School District 204

2021 IL App (3d) 190477
CourtAppellate Court of Illinois
DecidedJune 22, 2021
Docket3-19-0477
StatusPublished
Cited by1 cases

This text of 2021 IL App (3d) 190477 (Joliet Township High School District 204 v. Illinois Property Tax Appeal Board Joliet Township High School District 204) 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
Joliet Township High School District 204 v. Illinois Property Tax Appeal Board Joliet Township High School District 204, 2021 IL App (3d) 190477 (Ill. Ct. App. 2021).

Opinion

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

2021 IL App (3d) 190477

Order filed June 22, 2021 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

JOLIET TOWNSHIP HIGH SCHOOL ) Appeal from the Illinois Property DISTRICT 204, ) Tax Appeal Board ) Petitioner-Appellant, ) Appeal Nos. 3-19-0477 ) 3-19-0478 v. ) ) Circuit Nos. 14-00290.001-C-3 ILLINOIS PROPERTY TAX APPEAL ) 15-00588.001-C-3 BOARD, ) ) Respondent-Appellee. ) ___________________________________________________________________________

JUSTICE LYTTON delivered the judgment of the court. Justices Holdridge and Wright concurred in the judgment. ____________________________________________________________________________

ORDER

Held: Decisions of Illinois Property Tax Appeal Board (PTAB) to reduce tax assessments of nursing home were not against the manifest weight of the evidence despite PTAB’s failure to determine the precise building and lot sizes of the property where the evidence presented by a licensed appraiser showed that regardless of the building and lot sizes, the assessed values of the property were too high.

¶1 The Parc at Joliet, the owner of a nursing home in Will County, challenged the county’s

assessments of the value of its building for the 2014 and 2015 tax years. The Will County Board of Review affirmed the assessments. The Parc filed an appeal with PTAB. Petitioner Joliet

Township High School District 204 (District 204) intervened in the appeal. PTAB found that Will

County overvalued the property in tax years 2014 and 2015 and ordered the assessments to be

reduced. District 204 appealed, arguing that PTAB’s decisions were against the manifest weight

of the evidence. We affirm.

¶2 BACKGROUND

¶3 The subject property is a skilled nursing facility in Joliet. The facility has 203 beds, of

which 8 are private and 195 are semi-private. In addition to residential rooms, the facility has

therapy and dialysis areas, nursing stations, a dining room, kitchen, laundry, administrative offices,

and utility areas. Most of the building was constructed in 1969, with additions built in 2011. The

parking lot of the facility contains approximately 63 parking spaces. The Joliet Township property

record card for the property lists the building size as 63,894 square feet. The property record card

lists the lot size of the property as 2.4393 acres. An Illinois Real Estate Transfer Declaration

completed in 2007 lists the lot size of the property as 2.32 acres.

¶4 For tax years 2014 and 2015, Will County assessed the subject property at $1,456,659,

with the value of the land assessed at $194,573, and the value of the building assessed at

$1,262,086. The Parc challenged the county’s assessment by filing an appeal with the Will County

Board of Review. The Board of Review affirmed the assessment.

¶5 The Parc filed appeals with PTAB for tax years 2014 and 2015. The Parc did not contest

Will County’s assessment of the land but contested the value of the building itself and the value

of the total property. In its 2014 appeal, The Parc asserted that the assessed value for its building

should be reduced to $472,027, for a total assessed value of $666,660 for the entire property. In its

2 2015 appeal, The Parc asserted that its building should be assessed at $338,707 for a total property

assessment of $533,280. District 204 filed requests to intervene, which PTAB granted.

¶6 The Parc provided PTAB with a 180-page appraisal authored by John VanSanten and

Nicholas McGinn, in which they determined the value of the entire subject property was

$2,000,000. In response, the Will County Board of Review provided PTAB with two eight-page

documents, plus exhibits, from the Joliet Township Assessor’s Office, arguing that the appraisal

submitted by The Parc “should be given little or no weight.” According to the Board of Review’s

documents, signed by Joliet Township Assessor Jim Brenczewski and Deputy Assessor Dale D.

Butalla, the subject property had a value of $4,600,000 in 2014, and $5,000,000 in 2015.

¶7 On May 30, 2018, PTAB held a consolidated hearing on The Parc’s appeals for the 2014

and 2015 tax years. The Parc’s first witness was David M. Aronin, a certified financial planner

who provides financial and clinical consulting to nursing homes. He testified that he has reviewed

financial information for nearly 100 nursing facilities. He believed The Parc was not more

financially successful because of the age of the facility and the lack of bathing facilities in every

room. He testified that these features of the facility prevent it from attracting higher paying

residents, including Medicare recipients.

¶8 The Parc’s second witness was Charles Slagle, a nursing home administrator, who has been

operating the Parc since 2013. In 2014 and 2015, The Parc had an occupancy rate of 65%, which

Slagle attributed to the age of the facility and its poor reputation in the community. Two features

of the facility preventing it from attracting new residents are the lack of (1) bathing facilities in

resident rooms, and (2) private rooms for each resident. While newer facilities have full bathrooms

attached to each resident room, The Parc has a common shower/bath facility that residents share.

Additionally, the Parc has only eight private rooms, which are reserved for residents who must be

3 isolated because of medical conditions, such as infections. The remainder of The Parc’s rooms are

semi-private, shared by two residents. Slagle estimated that the average occupancy rate of nursing

homes in Illinois is 75-80%.

¶9 The Parc’s third witness was John VanSanten, a certified real estate appraiser licensed in

Illinois and other states. He has worked as an appraiser for 26 years and has authored thousands

of appraisals, including hundreds for nursing homes. Approximately 90% of his work involves

valuing health care real estate, including nursing homes. PTAB accepted him as an expert in

appraising real estate and, specifically, in appraising nursing homes.

¶ 10 VanSanten performed appraisal reports of the subject property in 2014 and 2015, opining

that the facility had a value of $2,000,000 in both years. He testified that 95% of the facility was

45 years old in 2014, while a 3,500-square-foot addition added in 2011 represented 5% of the

building, resulting in a weighted age of 43 years in 2014. After touring the facility, he found the

square footage stated on the property record card was incorrect. He determined the building

consists of 61,095 square feet and the lot consists of 2.42 acres.

¶ 11 VanSanten described the facility as being in fair to average condition overall. He noted the

building showed significant wear and tear in some areas. He determined the effective age of the

property was 35 years because of maintenance issues as well as the functional obsolescence in the

building design because of shared rooms.

¶ 12 In preparing his appraisal, VanSanten used three approaches to determine the value of the

subject property: (1) the cost approach, (2) the income approach, and (3) the sales comparison

approach. He testified that he gave primary consideration to the cost approach because nursing

homes are special purpose properties. Under the cost approach, VanSanten determined the value

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cumberland Acquisition, LLC v. Illinois Property Tax Appeal Board
2025 IL App (1st) 241868 (Appellate Court of Illinois, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2021 IL App (3d) 190477, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joliet-township-high-school-district-204-v-illinois-property-tax-appeal-illappct-2021.