William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC

CourtNew Jersey Tax Court
DecidedMarch 21, 2025
Docket006933-2014; 008634-2015; 005134-2016; 004908-2017; 006265-2018; 007570-2019; 008551-2020
StatusUnpublished

This text of William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC (William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC) 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
William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC, (N.J. Super. Ct. 2025).

Opinion

TAX COURT OF NEW JERSEY

MICHAEL J. DUFFY Dr. Martin Luther King, Jr. Justice Building Judge 495 Dr. Martin Luther King, Jr. Blvd., 4th Floor Newark, New Jersey 07102 Tel: (609) 815-2922, Ext. 54580

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

March 19, 2025

William E. Dolan, pro se Kenneth A. Porro, Esq. 99 West Hill Road Chasan Lamparello, Mallon & Cappuzzo, P.C. Woodcliff Lake, New Jersey 07677 300 Lighting Way, Suite 200 Secaucus, New Jersey 07094

Gregory S. Schaffer, Esq. Garippa, Lotz & Giannuario, P.C. 66 Park Street Montclair, New Jersey 07042

William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC Docket Nos.: 006933-2014; 008634-2015; 005134-2016; 004908-2017; 006265-2018; 007570-2019 and 008551-2020

Dear Mr. Dolan, Mr. Porro and Mr. Schaffer:

Plaintiff, William E. Dolan, and Defendants, the Borough of Woodcliff Lake

(the “Borough”) and BMW of North America, LLC (“BMW”), are involved in several related tax

appeals regarding two parcels in Woodcliff Lake. This letter shall constitute the court’s opinion

on Plaintiff’s motion to amend the complaints for tax years 2015 through 2020 and to strike

BMW’s proofs, including but not limited to any expert reports, and the Borough’s cross-motion to

dismiss the complaint for failure to comply with the court’s Case Management Order,

dated March 20, 2024, and for failing to state a claim for which relief can be granted.

For the reasons stated herein, the court denies both motions. Moreover, the parties are to

participate in a mandatory in-court settlement conference on or before Friday, May 16, 2025. William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC 006933-2014; 008634-2015; 005134-2016; 004908-2017; 006265-2018; 007570-2019 and 008551-2020 Page -2-

I. Facts and Procedural History

Plaintiff is the owner of real property and improvements located within the borough.

BMW is the owner of the real property and improvements on two parcels identified on the

municipal tax map as Block 602, Lot 1 and Block 802, Lot 1, commonly known as 300 and 200

Chestnut Ridge Road, Woodcliff Lake (collectively “Subject Properties”). The Borough is the

taxing authority for the Subject Properties.

Block 602, Lot 1 contains a 204,273 square foot office building (“Building 300”) situated

on 21.18 acres. Block 802, Lot 1 contains four buildings situated on 63.81 acres: a 130,169 sq ft

office building (“Building 200”); a 103,480 sq ft “training” building (“Building 250”); a 95,319

sq ft “engineering” building (“Building 150”) and a 4,650 sq ft maintenance garage. Both lots are

zoned for Office Research.

Since 2014, Plaintiff has filed a series of seven (7) third-party complaints against BMW

and the Borough alleging that the Subject Properties are under-assessed for tax years 2014 through

2020, causing the other property owners in the municipality to pay more than their fair share of

the tax burden. Plaintiff has demanded that the assessments on the Subject Properties be rendered

void and vacated in order to establish the correct assessed value for the tax years at issue.

BMW answered Plaintiff’s complaint and filed a counterclaim to reduce the assessed value of the

Subject Properties for tax years 2015, 2018, 2019 and 2020.

In related litigation, BMW has filed direct appeals against the Borough alleging that the

Subject Properties are over-assessed for tax years 2014, 2016 and 2017. For tax years 2018 William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC 006933-2014; 008634-2015; 005134-2016; 004908-2017; 006265-2018; 007570-2019 and 008551-2020 Page -3-

through 2020, BMW filed direct appeals alleging that Block 602, Lot 1 was over-assessed. 1

For tax years 2019 and 2020, the Borough filed counterclaims alleging that Block 602, Lot 1 was

under-assessed.

On April 30, 2024, Plaintiff filed a motion to: (1) suppress BMW’s proofs, including but

not limited to any expert reports 2 and (2) amend the complaints for tax years 2015-2020, to contest

the automatic fire suppression system exemption on the Subject Properties. 3 On May 9, 2024, the

Borough filed a cross-motion to dismiss the complaint for failure to comply with the court’s

Case Management Order, dated March 20, 2024, and for failing to state a claim for which relief

can be granted. At issue are these motions. 4

1 BMW of North America, LLC v. Borough of Woodcliff Lake, Tax Court Docket Nos: 004646- 2014; 008035-2016; 007534-2017; 005342-2018; 007001-2019; 004411-2020 (the “BMW direct appeals”). On July 16, 2024, this court entered an Order to Show Cause why the Plaintiff’s third-party actions should not be consolidated with the BMW direct appeals. On September 25, 2024, the court heard oral argument and reserved its decision on consolidation. 2 Plaintiff also sought to suppress the Borough’s proofs for failing to turn over its expert report in accordance with a March 20, 2024, case management order. The Borough does not deny the existence of an expert report, but asserts that its report was not prepared in the context of Plaintiff’s litigation, but with the BMW direct appeals. The court, therefore, will address Plaintiff’s motion to suppress the Borough’s proofs along with the Order to Show Cause in a separate decision. 3 In his motion, Plaintiff sought to add a claim of perjury allegedly based on BMW fraudulently obtaining the automatic fire suppression system exemption under N.J.S.A. 54:4-3.130 to – 3.137. During a status conference with the parties on July 9, 2024, the Tax Court questioned whether it had jurisdictional authority to address a perjury claim and asked Plaintiff as to the specific remedy being sought. Plaintiff responded that the exemption should be revoked and relief should be related to the taxes.

The Tax Court is a court of limited jurisdiction and does not have the authority to address a claim of perjury. See R. 8:2. Rather, the court will liberally construe Plaintiff’s motion as a request to amend the complaints to add a claim under N.J.S.A. 54:4-3.135(c). 4 On May 16, 2024, Plaintiff submitted a response to the Borough’s cross-motion and, on May 18, 2024, Plaintiff submitted a reply brief. With leave of court, BMW filed opposition to William E. Dolan v. Borough of Woodcliff Lake and BMW of North America, LLC 006933-2014; 008634-2015; 005134-2016; 004908-2017; 006265-2018; 007570-2019 and 008551-2020 Page -4-

On May 22, 2024, these cases were transferred from Judge Jonathan A. Orsen to Judge

Michael J. Duffy. Oral argument was heard on September 25, 2024.

II. Legal Analysis

A. Motion to Dismiss for Failure to State a Claim

The court will address the Borough’s cross-motion first, as it is dispositive in nature, and

could otherwise conclude the litigation. The Borough asserts that the complaints should be

dismissed because Plaintiff “cannot proceed without an appraisal report” for the Subject Properties

and, thus, cannot overcome the presumption of correctness associated with property tax

assessments. The Borough’s argument is premature and its motion to dismiss is denied without

prejudice.

A municipality’s tax assessment is entitled to a presumption of correctness.

Pantasote Co. v. Passaic, 100 N.J. 408, 413 (1985). The taxpayer has the burden to present

sufficient competent evidence to overcome the presumption and to establish a debatable question

about the validity of the assessment. Aetna Life Ins. Co. v. Newark, 10 N.J. 99, 105 (1952). Such

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