Oliveira v. Township of Edison

CourtNew Jersey Tax Court
DecidedAugust 25, 2017
Docket000490-2017
StatusUnpublished

This text of Oliveira v. Township of Edison (Oliveira v. Township of Edison) 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
Oliveira v. Township of Edison, (N.J. Super. Ct. 2017).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

TAX COURT OF NEW JERSEY

Mala Sundar R.J. Hughes Justice Complex JUDGE P.O. Box 975 25 Market Street Trenton, New Jersey 08625 Telephone (609) 943-4761 TeleFax: (609) 984-0805 taxcourttrenton2@judiciary.state.nj.us August 24, 2017

BY ELECTRONIC MAIL Caitlin Oliveira, Pro Se Lawrence Harbor, New Jersey 08816

Frederick L. Rubenstein, Esq. James P. Nolan & Associates, L.L.C. 61 Green Street Woodbridge, New Jersey 07095

Re: Oliveira v Township of Edison Block 1145, Lot 9 Docket No. 000490-2017

Dear Counsel and Ms. Oliveira:

This is the court’s opinion with respect to the plaintiff’s summary judgment motion seeking

to cancel defendant’s assessor’s added partial assessment for a portion of tax year 2016 because

such type of assessment has never been legally recognized. Plaintiff alternatively argues that if

such type of assessment is legally allowed, then the added partial assessment is improper because

the above captioned property (“Subject”) was not “substantially completed” and ready for its

intended use. Defendant (“Township”) opposed the motion claiming there were material facts in

genuine dispute as to whether the Subject was substantially completed.

For the reasons stated below, the court holds that the Township’s imposition of an added

partial assessment was lawful. There is however a materially disputed issue as to whether the

* discrete areas on the first floor (i.e., the lack of flooring over the existing concrete floors in the

foyer, main hallway and dining room), and the exterior (gutters and landings) render the first floor

as not being substantially complete. Therefore, the court denies plaintiff’s summary judgment

motion. It will hold a hearing as to whether the first floor was substantially complete, and

thereafter, hold a trial on valuation.

FACTS AND PROCEDURAL HISTORY

Plaintiff owns the Subject, which is a residential lot. The lot was classified and taxed as

vacant land for tax year 2016. Plaintiff is in the process of constructing a two-story single family

home on the Subject, which also includes a one-car attached garage, pursuant to a single permit

issued by the Township. Sketch plans showed the first floor having a family room, dining room,

kitchen, laundry room (with a closet), and the fifth bedroom with closets, and a full bath. The

second floor is to have four bedrooms and two full baths.

On July 18, 2016, plaintiff applied for, and received a temporary certificate of occupancy

(“TCO”). The TCO was valid for three months. Per plaintiff, the Township issues renewable

TCO’s for three-month periods. On the TCO, the “description of the work” on the Subject was

stated as “demo of existing structure to slab and construct addition and interior alteration.” The

TCO was subject to the condition “Occupancy of 1st Floor Only and No Use of Garage.” If that

condition was not met by 10/16/2016, then plaintiff would be subject to fines or required to vacate.

In conjunction with the TCO, the Township also issued plaintiff approvals for building, electrical,

fire protection, and plumbing. Each approval noted “TCO 1st Floor.” The approval for building

also noted that “garage not for parking car.” Those approvals were issued after due inspection by

the respective Township officials, per plaintiff.

2 Plaintiff’s statement of undisputed material facts alleged that the several rooms on the first

floor required minor work but were essentially completed. However, the entrance foyer and

hallway had unfinished concrete floors. She also claimed that the flooring was not yet installed in

the dining room on the first floor since it is being used as a “staging and storage area for building

materials and tools.” She stated, and the Township agreed, that the second floor of the house was

yet to be finished in several major aspects.

On August 16, 2016, a field inspector for the Township’s assessor’s office (hereinafter

“field inspector”), who is a certified real estate appraiser, performed an inspection (including the

interior) of the Subject. His notes indicated that the flooring in the foyer and dining room was “to

be installed.” The other rooms on the first floor (including the bathroom), and HVAC were

“complete,” as was the exterior. He also noted that the various rooms on the second floor were

incomplete due to “unfinished drywalls [and plywood floorings] throughout bedrooms, closets,

hallways,” however, the “bathtub [and] Jacuzzi tub [were] installed.” He noted that the garage’s

drywalls had yet to be taped. He also noted “see photos” in connection with his inspection as to

the Subject’s construction condition.

The Township then issued plaintiff an added partial assessment of $82,200 (prorated for

five months August-December 2016 at $34,250) in October 2016. The property record card

indicated that final value of the Subject was $191,800 (allocated $74,600 to land and $117,200 to

improvement). The card also indicated a partial assessment of $156,800 (allocated $74,600 to land

and $82,200 to improvement).

Upon plaintiff’s query for clarification of the assessment, the field inspector responded that

the “total improvement value upon completion will be $117,200 and ‘as of right now’ the

improvement value is $82,200.” He further explained the cost approach used to derive the

3 assessment, noted that the market approach was also used (listing six comparables), and provided

certain other clarifications.1 The assessor also confirmed to plaintiff that the added assessment

was issued “on the portion of the structure that was substantially completed – the part that received

the” TCO.2

On November 30, 2016, plaintiff filed an appeal to the Middlesex County Board of

Taxation (“County Board”) challenging the $82,200 added partial assessment for the

improvement. She reasoned that the Subject was “yet to be substantially completed and therefore

cannot be subject to 2016 added assessment.”

By judgment dated December 16, 2016, the County Board affirmed the assessment using

judgment code 14A. That code stands for “added assessment affirmed – as filed by assessor.”

Plaintiff then filed a timely complaint to this court. The standard form complaint alleged

that she was contesting the County Board’s action “on the ground that the assessment . . . is . . . in

excess of the true or assessable value of the property.” On the supplemental information sheet,

plaintiff alleged that since the “structure was not substantially completed during the 2016 tax year

[it] was erroneously issued a 2016 Added Assessment.” She noted that the assessor had deemed

the Subject to be “at a mere 70% completion as of October 1, 2016,” and reliance on the TCO was

improper since the TCO only covered “less than 50% of the structure’s square footage.” She also

alleged that since added assessments can only be issued upon substantial completion of a structure

as a whole, with no such “provision for partial completion or substantial partial completion of a

1 Plaintiff made a similar query to the Township’s assessor regarding the partial assessment imposed for tax year 2017 ($156,800) which she had appealed to the County Board.

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Oliveira v. Township of Edison, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliveira-v-township-of-edison-njtaxct-2017.