United Development of America LLC v. Paterson City

CourtNew Jersey Tax Court
DecidedJune 5, 2019
Docket001142-2014, 012633-2016
StatusUnpublished

This text of United Development of America LLC v. Paterson City (United Development of America LLC v. Paterson City) 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
United Development of America LLC v. Paterson City, (N.J. Super. Ct. 2019).

Opinion

TAX COURT OF NEW JERSEY

Joshua D. Novin Washington & Court Streets, 1st Fl. Judge P.O. Box 910 Morristown, New Jersey 07963 Tel: (609) 815-2922, ext. 54680 Fax: (973) 656-4305

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

June 4, 2019

Elsbeth J. Crusius, Esq. Law Offices of Elsbeth J. Crusius, LLC 267 Summit Avenue Hackensack, New Jersey 07601

David J. Yanotchko, Esq. Florio Kenny Raval, LLP 125 Chubb Avenue Suite 310-N Lyndhurst, New Jersey 07071

Re: United Development of America LLC v. Paterson City Docket Nos. 001142-2014 and 012633-2016

Dear Ms. Crusius and Mr. Yanotchko:

This letter constitutes the court’s opinion following trial of plaintiff, United Development

of America LLC’s (“United Development”), challenge to the 2014 and 2016 local property tax

assessments on its improved property in Paterson City (“Paterson”). 1

For the reasons stated more fully below, the court affirms the 2014 and 2016 local property

tax assessments.

1 Trial also included docket number 007338-2017. However, because United Development failed to present any evidence during trial of the subject property’s market value as of the October 1, 2016 valuation date, the court granted Paterson’s motion, under R. 4:37-2(b), to dismiss the complaint as to docket number 007338-2017. 1 I. Procedural History and Factual Findings

Pursuant to R. 1:7-4, the court makes the following findings of fact and conclusions of law

based on the evidence and testimony offered at trial.

Plaintiff is the owner of the real property and improvements located at 44-48 Ryle Avenue,

Paterson, New Jersey. The property is identified on Paterson’s municipal tax map as Block 801,

Lot 16 (hereafter referred to as the “subject property”). 2

The subject property is a K-shaped, 1.94-acre lot, containing frontage along Ryle Avenue

and Geering Lane (a/k/a Ryle Road). The subject property is located in Paterson’s First Ward, in

close proximity to the Great Falls National Historical Park and Paterson’s downtown area. The

subject property is bordered to the south and southeast by the Passaic River. Thus, the rear portions

of the subject property slope downward toward the Passaic River.

The subject property contains “mill-style” industrial buildings, constructed in the early

1900’s, consisting of approximately 44,495 square feet. 3 One of the buildings consists of three

distinct segments, a front two and part three-story segment located on the corner of Ryle Avenue

and Geering Lane, a middle one and part-two story segment located along Geering Lane, and a

rear, narrower, one-story segment, running parallel to and set back from Geering Lane. Generally,

the buildings were in a poor and run-down condition and were unoccupied as of the valuation dates

involved herein.

2 United Development acquired the subject property on September 19, 2013, from Wells Fargo Bank, NA for a reported consideration of $60,000. 3 The expert’s (as hereinafter defined) appraisal report and trial testimony was that only one three- part building was erected on the subject property. However, the expert’s street-level and satellite photographs of the subject property and the expert’s flood map and handwritten lot lines on the flood map depict that two separate buildings are erected on the subject property. Based on the trial record, the court is uncertain whether the 44,495 square foot measurement includes one or both buildings. 2 At trial, United Development offered testimony from a State of New Jersey Certified

General Real Estate Appraiser, who was accepted by the court, without objection, as an expert in

the field of property valuation (the “expert”). The expert prepared an appraisal report expressing

his opinion of the true or market value of the subject property as of the October 1, 2013, and

October 1, 2015 valuation dates. Paterson offered no testimony from any valuation professional.

As of each valuation date, the subject property’s tax assessment, implied equalized value,

and the expert’s value conclusion is set forth below:

Average ratio Implied Expert’s Valuation Tax of assessed equalized concluded date assessment to true value value value 10/1/2013 $2,349,400 124.81% 4 $2,349,400 $120,000 10/1/2015 $1,254,500 90.52% $1,385,882 $120,000

As of the valuation dates at issue, the subject property was located in Paterson’s I-1

industrial zoning district, with permitted uses that included business or professional offices, dry

cleaning establishments/laundromats, light industrial/manufacturing, wholesaling establishments,

motor vehicle sales, business services, warehousing and storage, research laboratories,

governmental offices, educational institutions, trade or technical schools, child care centers, public

parks, public utility facilities, off-street parking facilities, and outdoor storage. 5 Thus, according

to the expert, the subject property was a “legal conforming use of the site as is.”

The expert further offered his opinion that approximately “75% - 80% of this lot is in the

[Passaic River regulatory] floodway and the remaining 10% - 15% is in the AE flood zone. It just

4 When the Chapter 123 ratio is greater than 100% and the original assessment exceeds the court determined fair market value, then the assessment will be the fair market value. See N.J.S.A. 54:51A-6(c). 5 According to the expert, the subject property was located in Paterson’s Great Falls Historic District Redevelopment Area from 1978 to 2008. In 2008, the redevelopment plan expired and the subject property reverted back to the I-1 industrial zoning district. 3 floods, that area of the city just floods. . . .” However, based on the court’s review of the flood

hazard map, testimony elicited from the expert during cross-examination, and the expert’s

handwritten schematic of the subject property’s boundaries on the flood map, approximately 100%

of the front building segment and approximately 75% of the middle building segment are located

outside of the AE Special Flood Hazard Area. However, a small portion of the middle building

segment is located in what the expert termed, the “150 year floodplain,” 6 and 100% of the rear

building segment, and the entire second industrial building are located in the AE Special Flood

Hazard area. 7

II. Conclusions of Law

A. Presumption of Validity

“Original 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). “Based on this presumption, the appealing taxpayer has the burden of

proving that the assessment is erroneous.” Pantasote Co. v. Passaic City, 100 N.J. 408, 413 (1985).

“The presumption of correctness . . . stands, until sufficient competent evidence to the contrary is

adduced.” Little Egg Harbor Twp. v. Bonsangue, 316 N.J. Super. 271, 285-86 (App. Div. 1998).

6 The court concludes that the orange highlighted section on the flood map referred to by the expert were the “[m]oderate flood hazard areas, . . . the areas between the limits of the base [100- year] flood and the 0.2-percent-annual-chance (or 500-year) flood.” https://www.fema.gov/flood- zones (last visited May 30, 2019). 7 According to the expert, United Development listed the subject property for sale in 2013 with a real estate broker and received no purchase offers. However, the expert did not review the listing agreement, did not confer with the real estate broker, and did not know when the listing expired.

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