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Redacted April 17, 2005

In the spirit of collaboration we have removed personal references to former and current   elected Village officials.

-------------------------------------------------------------------------------------------

Thomas C. Hutton

 Elisabeth S. Harding

39 Homesdale Road

 Bronxville, N.Y.  10708

    January 31, 2005

 

     Mayor Nancy Hand

     Members of the Village Board of Trustees

     Village of Bronxville

     200 Pondfield Road

     Bronxville, New York  10708

 

 

    Re:  Village-Wide Real Property Revaluation

 

Dear Mayor Hand and Members of the Bronxville Village Board of Trustees:

             We are writing with respect to the immediate need for a Village-wide revaluation/reassessment of all parcels of residential and commercial real property.

             Over the past eight months we have reviewed many documents relating to the Village of Bronxville’s real property assessment rolls which we have obtained from the Village, the Town of Eastchester, and the State of New York pursuant to Freedom of Information Law requests.  We have also reviewed articles from the 1966 and 1967 editions of the Bronxville Review Press which covered the last Village-wide revaluation/reassessment which was completed in 1967.

             While we were originally interested in determining what, if anything, could be done to deter the flood of certiorari cases which continue to erode the Village’s tax base, we have been shocked to discover that since 1995, for all practical purposes, the Village has not reassessed any properties that have undergone major improvements.  This is an irresponsible fiscal policy.  At first, we thought this failure to reassess was limited to certain houses which had undergone major expansion projects such as the house of one of our neighbors which doubled in size a few years ago.  After reviewing each of the Village Assessor’s Annual Reports filed with the State from 1994 to 2004, however, we discovered that starting with the assessment roll completed in 1996, the Village in essence stopped reassessing any capital improvements until very recently.  (For copies of Part 2 of Annual Assessor’s Reports of the Village for 1994 - 2004 see Exhibit A). 

             During this nine year period, despite a huge boom in construction projects throughout the Village, assessments were increased on only 39 parcels of real property due to physical improvements to the properties.  This is an average of a little more than four properties a year.  This number represents a huge reduction from the 67 parcels the Village reassessed in 1994, and the 60 parcels it reassessed in 1995 (see Exhibit A).  These 39 Village reassessments are also in stark contrast to the over 600 parcels located in the Village whose assessments were increased by the Town of Eastchester during this period (1996-2004) for the Eastchester assessment rolls.* 

             The dollar amounts involved are not small.  Some of the estimated costs of these improvements ranged as high as $1,800,000 and the aggregate estimated cost of improvements for which construction permits were issued from 1996 through 2004 was $127,367,188.  Excluding the assessment increases attributable to the Avalon project, the Village’s assessment rolls only reflect assessment increases of $343,865, in the aggregate, for this period.  In contrast, if the Village had increased the assessment on the same village parcels and in the same percentages as the Town of Eastchester Assessor, the Village’s assessment rolls would have reflected increases of $4,664,208, in the aggregate, for this period.

             Reassessing properties that have increased in value due to improvements is not a matter of discretion.  Under the law the real property tax is a flat tax.  An owner of a parcel of real property that is worth $100,000 should pay twice as much in real property tax as the owner of a parcel that is worth $50,000.  To the extent an owner is able to improve the value of his parcel without a corresponding increase to the parcel’s assessed value, the tax rate on that parcel will be lower than the tax rate on other parcels.  This is not only inequitable, it violates Section 305 of the New York State Real Property Tax Law (“RPTL”).  This section provides in part that “all real property in each assessing unit shall be assessed at a uniform percentage of value.”

             We initially thought that the Village’s failure to reassess might have been the idea of the current Village Assessor, Robert Balog, who has certified the assessment rolls since 1996.  That appears unlikely, however.  A review of the assessment rolls in Hastings and Sleepy Hollow, where Mr. Balog is also the assessor, shows that in those communities the Assessor’s Annual Reports to the State for the years 1999 through 2004 reflect a consistent number of annual assessment increases.  (For copies of Part 2 of Assessor’s Annual Reports for Hastings 1999 - 2004 see Exhibit B; for copies of Part 2 of Assessor’s Annual Reports for Sleepy Hollow, 1999 - 2003, see Exhibit C).  It is difficult to imagine that Mr. Balog would find that capital improvements to parcels in Hastings and Sleepy Hollow increased the underlying value of those parcels while all the capital improvements to parcels in Bronxville added absolutely no value. 

 *  As you know the Village and the Town of Eastchester maintain separate and distinct assessment rolls.  The Village assessment roll determines the Village tax and the Bronxville School tax.  The Eastchester assessment roll determines the Townwide tax, the County tax, the Fire District tax and the County solid waste and sewer taxes.

            As we do not believe that this no-increase policy was the brainchild of Mr. Balog, we have spent many hours pondering why the Board of Trustees would adopt what we consider to be a secret and illegal tax abatement policy and we have settled on several possibilities.

1.   It is possible that this policy may have arisen out of some misguided notion to encourage residents and new buyers to renovate and upgrade the Village’s existing housing stock.  The recent construction project at the School and the pending renovation of Village Hall seem to reflect the vainglorious desire of some Village residents and officials to leave an indelible architectural mark on the Village. 

2.   We have also wondered if this policy had something to do with the Avalon project which came onto the Village assessment rolls in 1999 and 2000 and constituted the only assessment increases for those two years, $621,280 in 1999 and $980,000 in 2000.  (See Exhibit A).  Possibly these increases provided the incentive and wherewithal to mask the failure to reassess other improved properties.  This appears unlikely, though, since it should have been readily apparent that the exact amount of the increases to the Village’s assessment roll attributable to the Avalon is not permanent and inevitably will be challenged and rolled back by future certiorari cases. 

3.   We have also discussed the possibility that certain Village officials preferred to collect increased construction permit fees, which remain entirely with the Village, as opposed to collecting additional property tax revenue which must be largely given over to the School. 

4.   Redacted   

            In any event, regardless of the reasons for adopting this policy, over the past nine years the Village Assessor, either under the direction of, or with the tacit approval of, the Board of Trustees, has failed to increase the assessed value of hundreds of parcels of real property which have been subject to major capital improvements.  This policy obviously has benefited the owners of these parcels.  They not only pay lower annual taxes than they otherwise would, but they also can expect to be able to sell these properties at higher prices because the properties have lower tax burdens than they should.  While this policy has helped these affected owners, it has been at the direct expense of all the other Villagers who have never improved their parcels of real property or those who either happened to have made improvements to their parcels prior to 1995 or who happened to be the unlucky few who made improvements and were reassessed in 2003 and 2004. 

 

            This no-increase policy hurts the Village in other ways.  The inevitable inclusion of sales of these improved parcels in the calculation of the Equalization Rate for the Village will skew the calculation of this rate because these parcels should attain a higher market value than they would otherwise if they were properly assessed and taxed.  The resulting artificially high sales prices of these properties will only increase the already existing discrepancies in the market values between the family residential units and the cooperatives/condominiums.  This result will only further strengthen the flood of certiorari cases and will continue the erosion of the Village’s tax base.  Likewise, these artificially higher sales prices on these improved parcels will make it more difficult for a homeowner of an identically assessed parcel to claim that he is being overassessed.

             Reviewing the scope of the Village’s failure to increase assessments for major improvements during the period 1996-2004, it is clear that the Village's current assessment roll violates, and any subsequent assessment roll not based on a Village-wide revaluation will violate, Section 305 of the Real Property Tax Law.  (A copy of the Village’s Assessment Roll for the year 2004 can be found at Exhibit D and at www.bronxville.us.)  Hundreds of parcels of real property have been given tax breaks on millions of dollars worth of improvements at the expense of the other Village residents.  This is enough to irreparably distort the tax base.  In addition, the Village’s practice has exacerbated the problems with a tax base that was already legally untenable due to the inequities which have developed since the last time there was a Village-wide revaluation/reassessment.  (For more background on the Village's 1967 revaluation see Exhibit E).

             As part of our review of the Village’s records we have also discovered many irregularities in the Real Property Cards which represent the official assessment record for each parcel of real property in the Village.  These cards were developed during the Village-wide revaluation in 1967 and are considered so important that they are kept in the vault at Village Hall.  During our review of copies of approximately 200 cards we obtained through FOIL requests, we discovered that the dates on which assessments had changed were (a) predated, (b) post-dated, or (c) left blank entirely on many of the cards.  Given the nature of these mistakes it is difficult not to conclude that they were intentional acts rather than random acts of negligence.  In either event, the poor maintenance of Real Property Cards reflects another major problem in the Village's current assessment rolls. 

           For these reasons, we believe that the only way the Village can come into compliance with Section 305 of the RPTL is to institute a Village-wide revaluation/reassessment.  Based on our research, it is readily apparent that the Village Board of Trustees likewise has been contemplating the need for a Village-wide revaluation.  Several years ago the Board instructed Mr. Balog to perform a study of the Village assessment roll and what the effect of a reassessment might be on village properties.   The Board discussed the results of this study with Mr. Balog at an Executive Session held on October 14, 2002.  Clearly, such a study would not have been necessary unless the Board of Trustees believed in the first instance that a Village-wide reassessment was necessary.  (For a copy of Mr. Balog’s study see Exhibit F.)

         The mechanics of a Village-wide revaluation are straight forward.  As Mr. Balog cites in his study: 

       “The process of revaluation is extensive.  The RPTL outlines the process for the revaluation, and for the process for informing the public.  The revaluation process includes informal hearings on the proposed changes and assessment disclosure notices well in advance of the normal change of assessment notices.  The process is intended to give all property owners an opportunity to have more than the normal amount of time to examine their new assessment, to ask questions regarding their new assessment, and then to obtain their own information in order to ensure (or reassure) that the new assessment is correct.” 

Of course, the experience of the Village’s 1967 revaluation program also provides an excellent road map for developing a Village-wide revaluation in 2005. (See Exhibit E.) 

             We also note that in his study, Mr. Balog concludes that “revaluation could be anticipated to cost the Village approximately $180,000, with state aid contributing only $8,400 of that amount.”  Given the current debt burden attributable to the School construction and the proposed debt burden attributable to the renovation of Village Hall, we believe this is a small amount of expense to ensure that the costs of these projects, along with the ongoing operation of the Village and a highly rated school system, are shared fairly and equitably by all the Village’s residents.

             In order to provide you and the other recipients of this letter with a better idea of what we have learned with respect to the need for a Village-wide revaluation, we have set out below a more detailed discussion of the following subjects:

1.   Duties of the Assessor

2.   Annual Assessor’s Reports for the Village of Bronxville for Assessment Rolls completed in 1996-2004

3.   Construction Cost Estimates filed with Applications for Building Permits to the Bronxville Building Department for the period 1995-2003

4.   Annual Assessor’s Reports for the Village of Bronxville for Assessment Rolls completed in 1994 and 1995

5.   Annual Assessor’s Reports for the Town of Eastchester for Assessment Rolls completed in 1996-2004

6.   Irregularities Found in the Real Property Cards

7.   Redacted

8.   Brief History of the Village-wide revaluation in 1967

9.   Changes in Neighborhood Market Conditions After 1967       

            

 1.        Duties of the Assessor

             The duties of a municipality’s assessor are straight forward.  According to the New York State Board of Equalization and Assessment (SBEA), “(t)he assessor maintains the assessment roll document that contains every property’s assessment.  To do this, the physical description, or inventory, and value estimate of every parcel of real property in the municipality is kept up to date.”  In addition “(n)ew construction and major improvements to existing structures are inspected in order that the record of each property’s physical inventory is current, and the appropriate improvements are assessed.”  (emphasis added, see Exhibit G).  Each year the SBEA also requires the assessor to file annual reports on assessment changes, both increases and decreases.  These reports are broken up into two separate parts.

             Part I of these annual reports is a summary of increases and decreases in the total assessed value of locally assessed properties from the prior real property tax roll to the current roll.  Part I also contains a certification by the assessor that the information contained in the report constitutes a true statement of fact and is derived from the finalized assessment roll and that the accompanying computerized data file supports the data provided in this report and is a copy of the file used to produce the assessment roll.  For your information we have enclosed a copy of Part 1 of the Village’s 1997 annual report which was certified by Mr. Balog.  (See Exhibit H).

             Part 2 of the assessor’s annual report is the detailed listing of the changes to the prior year’s tax roll.  Pursuant to a FOIL request to the NYS Office of Real Property Services, we were able to obtain copies of all the annual reports filed by the Village with respect to tax years 1994-2004.  You will find copies of Part 2 of each of these reports listed as Exhibit A.  As an aside, we have been informed by Mr. Porr that copies of these reports, except the most recent one, are not maintained by the Village and, therefore presumably the Village Assessor who is an officer of the Village.  Given that these reports, particularly Part 2, are the only realistic way to track the history of the increases and decreases in the Village’s tax roll, we find the Village’s failure to maintain copies of such reports quite disturbing.

 2.        Annual Assessor’s Reports for the Village of Bronxville, 1996-2004

             A review of Part 2 of the Village Annual Assessor’s Reports for the 1996-2004 assessment rolls reveals that there were 39 increases for properties due to capital improvements.  Two of these increases related to the completion of the Avalon Apartments.  The 1999 Annual Report shows an increase of $621,280 and the 2000 Annual Report shows an additional increase of $980,000 with respect to the Avalon.  Other observations on the remaining 37 increases are set forth below year by year.

 1996  Four of the increases related to parcels located at 11,12,15 and 16 Beverly Road  (designated by section/lot numbers as (23./8/3), (23./8/4), (23./8/5), and (23./8/6).  Another increase related to the parcel located at 3 Westway and owned by Village Trustee Frank Sica (section/lot number 7.A/2/5).  This parcel shows an increase of $13,400 but this amount was totally offset by the elimination of the assessed value on another parcel owned by Mr. Sica (section/lot number 7.A/2/1).  There was also an increase of $15,200 on the parcel located at 78 Tanglewylde (section/lot number 14./3/1) and there was an increase of $25,000 for the parcel located at 37 Greenfield Avenue (section/lot/number 17./3/11) which reflected the completion of a new house on the location of a previous house which had been torn down.  The other two increases for this year were $5,300 for the parcel located at 12 Elm Rock Road (section/lot no. 6.F/1/2) and an increase of $5,000 for the parcel located at 6 Paradise Road (section/lot 18./7/1).

 1997  Except for an increase which was totally offset by a corresponding decrease in the assessed value of an adjoining property, there were two increases in this year.  The first was an increase of $32,000 on the parcel located at 15 Hawthorne Road (section/lot no. 6.C/1/7) which reflected the reconstruction of the house which had been destroyed by a fire.  The second increase was for $10,865 and reflected an additional increase for the parcel located at 78 Tanglewylde (section/lot no. 14./3/1).

 1998    There were no increases this year.

 1999    Except for the increase related to the Avalon Apartments there were no increases this year.

 2000    Except for the increase related to the Avalon Apartments there were no increases this year.

 2001    Except for an increase which was totally offset by a decrease in the assessed value of an adjoining parcel, there were no increases this year.

 2002    Except for an increase which was totally offset by the decrease in the assessed value of two parcels owned by the same family, there were no increases this year.

 2003    There were 16 increases in this year which in the aggregate totaled $112,900.  One increase, for $21,900, related to the parcel located at 18 Dusenberry Road (section/lot no. 7.H/4/7) and involved a major renovation of the previously existing house.

 2004    There were 7 increases in this year which in the aggregate totaled $48,900.  One increase, for $29,900, related to a parcel located at 10 Kraft Avenue (section/lot no. 3./2/15) and reflected the construction of a new house to replace the previous house that was destroyed by fire. 

            Excluding the assessment increases related to the Avalon Apartments and those increases which were totally negated by offsetting decreases, the Annual Assessor Reports for 1996 - 2004 reflect assessment increases in the aggregate of $343,865.

 

3.         Construction Cost Estimates filed with Applications for Construction                         Permits to the Bronxville Building Department, 1995-2003

             While it is difficult to compute the value of the capital improvements to parcels of real property during the period 1995-2003, a review of the construction cost estimates filed with the applications for construction permits for the same period provides a good guide in developing an order of magnitude.  For example, the construction cost estimates related to the Avalon Apartments were $6,178,485 and $5,000,000 in 1998.  As mentioned above, the assessment on this project was increased by $621,280 in 1999 and the assessment was increased by $980,000 in 2000.  In addition, while the aggregate construction cost estimates include improvements to tax exempt property owned by Lawrence Hospital ($7,525,000 in 1998) and Concordia College ($6,910,000 in 2001), it should be noted that in many cases the cost estimates provided on the applications for construction permits were probably much lower than the actual costs of completing these projects.  We have set forth below the aggregate construction cost estimates listed on the Village's Building Department Activity Reports for the years 1995-2003.

 

Year                         Cost Estimates

1995                            $5,112,502

1996                            $5,205,024

1997                            $6,352,200

1998                            $29,618,995

1999                            $13,182,967

2000                            $15,783,500

2001                            $21,791,000

2002                            $16,213,000

2003                            $14,108,000    

Total                          $127,367,188

 

4.      Annual Assessor’s Report for the Village of Bronxville for Assessment Rolls completed in 1994 and 1995

             The Village Assessor’s Reports for the assessment rolls completed in 1994 and 1995 were certified by the then Village Assessor John Galloway.  Part 2 of each of these reports is included in Exhibit A.

             A brief review of these reports reveals that Village assessments on 67 parcels of real property were increased in 1994 and the Village assessments on 60 parcels of real property were increased in 1995.  In the aggregate the total increases in assessed values were $179,000 in 1994 and $240,800 in 1995.  In addition, the aggregate construction cost estimates were $6,354,009 in 1993 and $6,084,925 in 1994. 

 5.         Annual Assessor’s Reports for the Town of Eastchester for Assessment Rolls completed in 1996 - 2004

             The Town of Eastchester has its own assessor whose office is distinct and separate from that of the Village Assessor.  The Village Assessor has responsibility for adjusting assessments, up or down, on parcels of real property on the Village assessment rolls.  The Village assessment roll is used only for purposes of determining the Bronxville Village tax and the Bronxville School tax.  In contrast, the Eastchester Assessor has responsibility for adjusting assessments, up or down, on parcels of real property located in the Village of Bronxville, the Village of Tuckahoe, and the unincorporated portions of Eastchester on the Town assessment roll.  The Town assessment roll is used to determine the Town-wide tax, County tax, Fire District tax, and County solid waste and sewer district taxes.

             In 1967, the Town of Eastchester revaluated its assessment rolls for the Village of Bronxville, Village of Tuckahoe and the unincorporated portions of Eastchester.  The Town used the same firm to perform this revaluation that Bronxville had hired to perform its Village-wide evaluation in the same year.  Consequently, the Town’s assessment roll with respect to parcels of real property in the Village of Bronxville was derived from the same market estimates used by the Village in determining its assessment roll.  The Town, however, used a different percentage of market value to develop its assessment roll and it has continued to maintain a separate assessment roll since 1967.

             The separate roles and legal responsibilities of the Eastchester Town Assessor and the Village Assessor are clearly set out in a letter, dated April 28, 1998, from Eastchester Town Supervisor Jim Cavanaugh to Mayor Hand.  Apparently this letter was prompted by a telephone conversation between Mayor Hand and the Eastchester Town Assessor, Richard O’Donnell, in which the Mayor called to relay the complaint of a Bronxville resident who had objected to the attempt of an appraiser from the Town of Eastchester to inspect improvements at his home.  (For a copy of Mr. Cavanaugh’s letter see Exhibit I.)

             In an apparent attempt to calm the inter-governmental waters and to explain the role of the Eastchester Assessor, Mr. Cavanaugh set forth in his letter the responsibilities of the Town of Eastchester as follows:

“As you know, the Town of Eastchester is responsible for maintaining an assessment roll in Bronxville for purposes of the Townwide tax, County tax, Fire District tax, and County solid waste and sewer districts.  All told these taxes constitute about 30 percent of a typical Village tax bill, so it is essential that the assessments be as accurate as possible.”

Mr. Cavanaugh also enclosed with his letter the pamphlet prepared by the New York State Board of Equalization and Assessment which explains the role of an assessor and which we referenced above.  With respect to the importance of site inspections, Mr. Cavanaugh also noted the following:

“It is the policy of the Town Assessor that all changes in assessments be based upon a site inspection.  This is consistent with State law.  It is also the policy of the Assessor that every reported instance of an improvement be addressed.  Not only are site inspections the norm for assessors statewide, anything less will lead to inaccurate assessments that penalize the taxpayers.”

 

            Consequently, although the Town maintains separate assessment rolls, it still works with the Village Building Department to obtain copies of building permits for construction projects within the Village.  A review of these permits provides the Town with the information it needs to schedule the physical site inspections that allow the Town Assessor to determine whether particular capital improvements warrant an increase in the properties’ assessed values.

             While it would be unfair to make an exact comparison between the assessment rolls of the Village and the Town of Eastchester because the Village and the Town have kept separate rolls since 1967, we do believe a comparison is instructive for demonstrating the extreme nature of Mr. Balog’s failure to increase the assessments on parcels of real property which have been subject to major improvements.  We were able to secure from the State and the Town of Eastchester paper copies of Part 2 for the Eastchester Assessor’s Annual Report for assessment rolls completed in 1997, 1998, 1999, 2000, 2001 and 2002.  (For copies of the pages of Part 2 of these reports that cover those parcels located within the Village of Bronxville see Exhibit J.)  In addition we were able to obtain electronic copies of these reports for the Eastchester assessment rolls for 1996, 2003, and 2004.  Unfortunately we were not able to convert these electronic files to appropriate paper copies as Exhibits.  However, for purposes of the discussion below we have used the information on these electronic files.

             As noted above, excluding the two assessment increases related to the Avalon project, there were 37 assessment increases due to major improvements on the Village assessment rolls completed for 1996-2004.  During this same period, excluding assessment increases related to the Avalon project, there were over 600 increases on the Town of Eastchester’s assessment rolls for parcels of real property located within the Village.  We have set forth below the number of increased assessments on a year by year basis for both the Village and Town of Eastchester.

 

 Increase on Village Roll Increase on Town Roll

                                     

            1996                          9                                                  18

            1997                          3                                                  92

            1998                          0                                                  60

            1999                          0                                                  73

            2000                          0                                                  75

            2001                          1                                                  76

            2002                          1                                                  70

            2003                          16                                                76

            2004                          7                                                  81  

                                              --------                                      ---------    

            TOTAL                     37*                                            621

 

*  Of this total, four assessment increases were offset by corresponding assessment decreases to related or adjoining properties. 

It is interesting to note that the annual number of Bronxville parcels subject to increased assessments by Eastchester during this period is in the same ballpark as the number of parcels which had increased assessments for the Village assessment rolls completed in 1994 and 1995 by Mr. Balog’s predecessor.

             Besides the different number of parcels which had increased assessments in Eastchester, it is also instructive to look at a sample of the percentage assessment increases on specific houses on the Eastchester assessment rolls whose assessments did not increase at all on the Bronxville assessment rolls.  Set forth below is a chart showing the estimated construction costs and the percentage increase on the Eastchester assessment roll for a sample of parcels located within the Village.  For a more detailed description of the construction cost estimates for these properties see Exhibit K.

                                               Construction Cost

                                                Estimate for                 % Increase in      % Increase in

                                                Bronxville                    Eastchester          Village

Address                                  Building Permit           Assessment         Assessment

106 Tanglewylde Ave.            $290,000                       36.80%              0

30 Elm Rock Rd.                    $500,000                       65.35%              0

47 Prescott Avenue               $649,000                       37.00%              0

22 Sturgis Rd.                      $300,000                       48.71%              0 

6 Leonard Road                    $250,000                       42.70%              0         

44 Masterton Road              $650,000                       65.00%                 0             

43 Dusenberry Road            $259,000                       14.89%                 0             

10 Courseview Road          $400,000                          31.6%                   0             

18 Ridge Road                   $1,200,000                      46.50%                 0             

12 Wood End Lane             $475,000                       47.20%                   0             

93 Tanglewylde Ave.           $350,000                       34.08%                    0             

87 Tanglewylde Ave.           $1,800,000                    98.60%                    0             

91 Tanglewylde Ave.             $750,000                       31.03%                  0 

10 Courseview Rd.               $400,000                       31.62%                    0

6 Greenfield Rd.                     $400,000                       21.61%                  0

5 Vine Street                          $400,000                       74.00%                    0

18 Ridge Road                      $1,200,000                    62.79%                    0

75 Summit Ave.                     $560,000                       43.2%                      0

35 Sturgis Ave.                       $800,000                       70.9%                      0

 

*91 Tanglewylde Ave. is also 24 Sycamore Street (See Exhibit L.)

            It is likewise instructive to compare the percentage assessment increases on some of the houses which were reassessed by the Village in 2003 with the percentage assessment increases on the Town of Eastchester’s assessment roll.  Set forth below is a chart showing the construction cost estimates on eleven of the sixteen parcels whose Village assessments increased in 2003 and the corresponding percentage increases on the Eastchester assessment roll and the Village assessment roll.  For a more detailed description of the construction cost estimates for these properties see Exhibit M.

 

                                                Construction Cost

                                                Estimate for                 % Increase in      % Increase in

                                                Bronxville                    Eastchester          Village

Address                                  Building Permit           Assessment         Assessment

11 Fordal Road                     $1,000,000                    50.64%                   8.7%

23 Homesdale                          $250,000                    10.59%                   9.9%

3 Pine Terrace                          $225,000                    12.94%                   9.1%

16 Sunnybrae                            $175,000                    14.25%                   8.5%       

22 Elm Lane                              $275,000                    14.21%                  19.4%               

321 Pondfield Rd.                      $550,000                    10.68%                   7.3%                   

58 Park Ave.                             $500,000                     56.4%                    28.5%                 

102 Tanglewylde Ave.                $150,000                     8.52%                    10.8%                 

9 Woodland Ave.                       $275,000                    18.24%                      6%                      

21 Ridge Road                           $370,000                     6.2%                       5.3%                   

8 Hobart Street                         $175,000                    32.11%                    22.4%                 

 

            Finally, we believe that it is interesting to review what the assessment increases would have been on the Bronxville assessment rolls completed for 1996-2004, if the Village Assessor had increased the assessments on the same parcels and in the same percentages as the Town of Eastchester Assessor did during this period.  We have set forth below the assessment increases reflected on the Bronxville assessment rolls year by year and our calculation of what the assessment rolls would have been if the Village Assessor had increased the assessment on the same parcels and in the same percentages as the Town of Eastchester Assessor.  The numbers below do not include assessment increases related to the Avalon project or those increases which were offset by a corresponding assessment decrease. 

 

                                          Actual Assessment Increases           Projected Assessment

Year  on Bronxville Rolls                                 Increases         

1996       $139,200                                          $183,759

1997           42,865                                           537,062

1998               0                                                 682,066

1999               0                                                 698,897

2000               0                                                 692,559

2001               0                                                 593,309

2002               0                                                 452,029

2003           112,900                                           400,491

2004             48,900                                           424,036

TOTAL    $343,865                           $4,664,208

 

It is interesting to note that the difference between the actual Village assessment increases and the projection of what these increases might have been if the Village had assessed the same parcels and used the same percentages as the Town of Eastchester is $4,320,343.  This number constitutes 5.8% of the Village’s Total Locally Assessed Properties of $74,563,514 as reported on the Village Assessor’s Annual Report completed for 2004.  Even if the Village had only reassessed at half the rate of the Town of Eastchester, the assessment increases would have totaled $2,281,757 or $680,477 more than the assessment increases of $1,601,280 related to the Avalon project.  We think this comparison punctuates the enormity of the Village’s failure to appropriately assess capital improvements during this period.  At a time of continuous certiorari cases and a declining tax base, we find it impossible to fathom what the Village Board of Trustees could have been thinking.

 

6.         Irregularities Found in the Real Property Cards

            As part of our series of FOIL requests to the Village, we asked for copies of the real property cards for 168 specific properties.  This number represented approximately ten percent of the parcels of real property that are listed on the Village’s current assessment roll.  As part of this list we asked for the cards for parcels owned by past and present Village and School officials as well as those cards for parcels of real property which to our knowledge had been subject to major improvements over the past ten years.  Among many things we were interested in discovering was whether the assessed values for these parcels had been increased during the time period that Mr. Balog has been the Village Assessor.

            At first, we were interested to find that in spite of contrary information on the Assessor’s Annual Reports, some real property cards indicated assessment increases in 1998 and 1999.  Our initial interest turned to concern, however, when we discovered that the property card for the property of one of our neighbor’s had been predated.  In reality, they were one of the first unlucky families in years to have their assessment increased.  This happened in 2003 after a construction project.  Oddly, however, the real property card for their residence indicated that the assessment increased in 1999 and not in 2003.  Given that the assessment change would not have been recorded on the card until the assessment roll for 2003 was completed, in the Spring of 2003, it seemed extremely curious that the card indicated that the change had been made in 1999. 

            This discrepancy also made us wonder about all the other cards showing assessment increases in 1998 and 1999, years in which the assessor’s report to the state shows no increases other than the Avalon.  We also became curious about the accuracy of the real property cards for those other parcels of real property that had assessment increases on the assessment roll completed in 2003.  Accordingly, we filed an additional FOIL request for the real property cards for these additional properties.  We also asked for the card for the property owned by Village Trustee Thomas Leslie.  By this time we had secured copies of the Village Assessor’s Annual Report for 2000 and had discovered that the assessment for Mr. Leslie’s house had decreased by almost 20 percent on that roll.

            After receiving the additional cards from the Village, we were dismayed to find three types of irregularities.  The dates of the assessment increases had been either predated, postdated, or left blank entirely.  With respect to these cards we specifically discovered the following:

             Postdated Cards:  We found three cards where the date of the assessment change had been postdated by two or three years.  The three cards all involved properties where the assessments had increased for the Assessment Roll completed in 1996.  (See Part II of the Annual Assessor’s Report for Bronxville for 1996 under Exhibit A.)  The date of the assessment increases marked on the cards, however, were as follows:  For Trustee Frank Sica’s house at 3 Westway (7H/2/5) the card states the assessment was increased in 1998; and for the house located at 42 Sturgis Road (7F/4/1) and the house located at 11 Eastway (7H/4/7) the cards incorrectly state that the assessment increases incurred in 1999.  (For copies of these cards see

Exhibit N.)

             Predated Cards:  We found three cards where the date of the assessment changes had been predated by three or four years.  The assessment on each of these properties was increased in 2003 (see Part 2 of Annual Assessor’s Report for Bronxville for 2003 under Exhibit A) but the cards for these properties reflected the following dates for these changes:  for 22 Elm Street (7G/5/5) the card reflects that the assessment was changed in 1998 and for the properties located at 321 Pondfield Road (8/5/9) and at 23 Homesdale Road (7E/4/14) the respective cards reflect that the assessments were increased in 1999.  (For copies of these cards see Exhibit O.)

             Undated Cards:  As mentioned above, after discovering the three postdated cards, we requested cards for the remaining properties whose assessments were increased in 2003.  On these cards we found that in each case the date for the assessment increase had been left blank.  (For copies of these cards see Exhibit P.)  We were also surprised to find that the date also had been left blank for the assessment decrease on the card for Trustee Leslie’s house at 92 Tanglewylde.  According to the Annual Assessor’s Report of the Village of Bronxville for 2000, the assessment on 92 Tanglewylde was decreased in 2000.

             We have been deeply troubled by the irregularities we have found in the real property cards that we have reviewed.  While we appreciate that “typos” can occur in documents, it is difficult to believe that someone filling in the assessment changes in the Spring of 1996 would mistakenly write down the year 1998 or 1999 instead of 1996.  It is likewise difficult to believe that someone filling in the assessment changes in the Spring of 2003 would mistakenly write down the years 1998 or 1999 instead of 2003.  The fact that the dates of the assessment increases were left blank on ten of the sixteen properties whose assessments were increased in 2003 and that the date of the assessment decrease on the card for Trustee Leslie's house on 92 Tanglewylde was left blank raises the possibility that as a matter of course the real property cards for all properties are not being maintained in a proper manner.  This is extremely alarming.

             Developed during the revaluation program in 1967, these property cards are the official record for each parcel of property located in the Village.  These cards are supposed to reflect the complete ownership record, including the dates and purchase prices of any sales, assessment records and the building record for each parcel of real property.  These cards are considered so important that they are kept in the Village vault and when we filed FOIL requests to review and copy some of these cards we were informed that the cards were too fragile to handle and that over time the Village would have copies made for us.

             Given the importance of these cards, the poor maintenance and irregularities we have found are unacceptable.  This is particularly true because we have been told by Mr. Porr that the Village does not maintain “custody and control” over the Annual Assessor Reports the Bronxville Village Assessor files with the state.  The real property cards are the major way of tracking the assessment history on any parcel of real property.  When the information on the card is either incorrect or incomplete, it is a very cumbersome process to reconstruct the assessment history of a house by reviewing previous years’ assessment rolls until the year in which the change in assessment occurred is located.  Before we received all the Annual Assessor Reports for the Village from the state, we spent several hours trying to trace the exact dates when the assessment changed on Mr. Sica’s house and other houses with predated and post-dated real property cards.  In the absence of a reasonable explanation to the contrary, it would appear that the real property cards have been poorly maintained on purpose to make such a search extremely difficult if not impossible.

7.         Redacted   

 8.         Brief History of the Village-wide Revaluation in 1967

             In the Spring of 1966, the Bronxville Village Board of Trustees approved a real property evaluation program to update the Village’s assessments.  In his explanation of this program to the Villagers, Mayor Edwin Russell set forth the program’s three primary objectives: 

The Village seeks to establish properly equalized assessment on all existing properties through the use of uniform bases and proven methods of systematic appraisals. 

The Village wishes to establish an up-to-date and complete set of records for all properties, so that the basis of each assessment can be readily verified by the assessor and understood by the taxpayer. 

The schedules and formulas developed in making the appraisal will be retained by the Assessor, and used in the future on the assessment of new buildings so that the proper relationship of assessment will be maintained. 

This program is not designed to increase the overall level of Village taxes.  It is simply an equalization program intended to insure that the Village and School tax on each property shall be in direct proportion to property values as required by law.  The Town and County tax will be based on the Town assessments.  It should be noted here that this program will not single out any area, type of property, age group or business property as a target.  The objective is simply to equalize all real property values in relation to their true market values.  (Bronxville Review Press, May 12, 1966, pg. 1) (See Exhibit E). 

            The Village hired Cole-Layer-Trumble Company of Dayton, Ohio, to perform the revaluation at a cost of $18,000.  (See Exhibit U for a copy of the Village’s contract with Cole-Layer-Trumble.)  Employees of this firm spent the summer and fall of 1966 inspecting properties throughout the Village.  At that time the Village had approximately 1,450 taxable properties of which approximately 1,100 were single family houses.  After the tentative roll was complete, but prior to Grievance Day, February 21, 1967, the Village hosted interviews with 540 property owners.  According to William Duke III, the Village’s then Administrator, “Taxpayers in Bronxville are well informed and know exactly why the equalization project was necessary.  Most come in with a figure in mind and before they leave they tell you how close the appraisal is.”  (Bronxville Review Press, Feb. 2, 1967).  Ultimately, 105 grievances were filed and upon review 47 appraisals were adjusted.  For a more detailed description of the Village's 1967 revaluation program we have included copies of Bronxville Review Press articles which were intended to set forth a very clear explanation of the program.  The newspaper also printed a series of articles by the then Village Administrator, William Duke III, and Cole-Layer-Trumble which were intended to provide background information with respect to planning a tax equalization program.  (See Exhibit E.)

 9.         Changes in Neighborhood Market Conditions After 1967

             When the 1967 revaluation program was complete, the tax roll reflected the physical condition of the Village’s real estate.  Those houses that were recently constructed were assigned a relatively high market value while the older houses, particularly the large Victorian houses in Lawrence Park, many of which were run-down, were assigned a lower market value.  Since 1967, however, many of these older houses have been beautifully updated and restored to their original mint condition.  Having been on many house tours, we both can attest to the quality of work that has gone into these houses.  Curiously, though, the assessed value of many of these houses has not increased from the low market values assigned in 1967 and we think it is fair to say that in general the houses in Lawrence Park are very underassessed.

             In this regard, we discovered that the Board of Trustees hired Mr. Balog to perform a study of what impact a Village-wide revaluation would have on property values in the Village.  According to the Board’s minutes, at an Executive Session held on October 14, 2002, “Mr. Balog discussed his study of the Village Assessment Roll and what the affect (sic) of a reassessment might be on village properties.  Mr. Balog will continue his review of the data.”

             When we first heard of Mr. Balog’s study we were very enthused.  First, the existence of such a study confirmed what we had heard through the Village grapevine despite denials from Village officials.  Secondly, it was clear that the Village Board of Trustees would not commission a report to study the effect a reassessment might have on village properties unless the Board thought that such a reassessment was appropriate and/or legally required.  Thirdly, if the study concluded that a reassessment would have a major impact on the value of village properties (both increases and decreases), that would not only substantiate the need for such a reassessment but it also would quantify the existing inequities inherent in the Village’s assessment roll.

             Our first FOIL request for Mr. Balog’s study was denied on the grounds that it was an intra-agency memorandum and accordingly exempt from FOIL.  We appealed this denial noting that pursuant to New York State Public Officers Law all factual/objective information appearing in narrative form or in “statistical or factual tabulations or data” in an “intra-agency report” such as Mr. Balog’s study should be publicly accessible.  By letter, dated September 17, 2004, Mayor Hand granted our appeal, in part, by providing us with a copy of Mr. Balog’s study which had been “redacted where appropriate and disclosing ‘statistical or factual tabulations or data.’”  See Exhibit V.

             When we received Mr. Balog’s study, we seriously considered filing an Article 78 Proceeding in order to request a judge to review the study in camera to determine whether all the redacted material consisted solely of the opinions and recommendations of Mr. Balog.  For example, it is readily apparent that in some places even the headings and titles of sections of the study have been redacted.  After further review we determined that the extreme lengths the Village has gone to hide the information in Mr. Balog’s study speak for themselves.  If the study had concluded that a reassessment would have little or no impact on the value of village properties it would likewise have concluded that the present assessment rolls are fair and in compliance with Section 305 of the Real Property Tax Law.  Accordingly it would have concluded that a reassessment was not necessary.  Given the Village’s reluctance to share Mr. Balog’s conclusions with the village taxpayers, we believe it is reasonable to conclude that, in fact, the study does show that a Village-wide reassessment would have a significant impact on the values of village properties, both increases and decreases, and accordingly supports the need for such a reassessment.  Supporting this position we have also been indirectly told by individuals who have seen this report that it concludes, in part, that many of the houses located in Lawrence Park are, in fact, underassessed.

             Even in its severely redacted form, moreover, we do believe that Mr. Balog’s report provides a great deal of useful information.  During our research we have been told by several people that a Village-wide revaluation would be cost prohibitive.  Accordingly it was enlightening to review Mr. Balog’s discussion of the cost of such revaluations in other communities and his estimate that such a revaluation in the Village would cost only $180,000.  It was also interesting to see that Mr. Balog’s description of what is involved in a revaluation paralleled the descriptions of what occurred in 1966-1967 when the Village had its last Village-wide revaluation.

 

10.       Conclusion

             After our lengthy review of the Village’s assessment records over the past eight months we have learned the following: 

a.   The Village maintains an assessment roll separate and distinct from the assessment roll for the Town of Eastchester. 

b.   The Village’s assessment roll is only used for determining the Bronxville village tax and the Bronxville school tax. 

c.   The Town of Eastchester’s assessment roll is used for determining the Town tax, the County tax, the Fire District tax and the County solid waste and sewer district taxes. 

d.   Although the Village assessment roll and the Town of Eastchester assessment roll have been separately maintained, they are both based on market values determined by the same firm that performed the last Village-wide revaluation in 1966-1967. 

e.   A review of the Village Assessor’s Annual Reports to the state shows that from 1996-2004 the Village failed to ensure that all major improvements to existing structures were appropriately assessed. 

f.    From 1995-2003, the construction cost estimates for capital improvements in the Village totaled approximately $127,000,000.  Excluding the cost estimates related to the Avalon project and projects at Lawrence Hospital and Concordia College, the cost estimates for construction costs were approximately $100,000,000 and presumably the final, actual costs for these capital improvements exceeded these estimates. 

g.   From 1996-2004, excluding the assessment increases related to the Avalon Project, there were 37 assessment increases on the Village assessment rolls which resulted in an increase of $343,865. 

h.   From 1996-2004, excluding the assessment increases related to the Avalon project, there were over 600 assessment increases on the Town of Eastchester’s assessment rolls for parcels of property located in the Village of Bronxville. 

i.    Although the Village and Town maintain separate and district assessment rolls, a review of the Town Assessor’s Annual Reports to the State for 1996-2004 are very instructive in demonstrating the enormity of the Village’s failure to appropriately assess major improvements during this time period.  If the Village of Bronxville had reassessed the same parcels of property that the Town of Eastchester did during the period 1996-2004 and had used the same percentage increase as that used by the Town, the Village's assessment rolls would have increased by $4,664,208. 

j.   Redacted  

k.   The Real Property Cards which are the only official reassessment records for each parcel of property in the Village have been poorly maintained either negligently or intentionally. 

l.    In 1966-67 there was a Village-wide revaluation program which provides an excellent precedent for the Village Board adopting a revaluation program in 2005. 

m.  Mr.Balog has studied the effect of a Village-wide reassessment on village property values and has discussed his study with the Board.  It is our understanding that this report confirms our belief that many of the properties located in Lawrence Park are underassessed. 

n.   Mr. Balog estimates that the cost of Village-wide assessment would be approximately $180,000 and his description of what such a reassessment program would entail is very similar to the Village’s reassessment program in 1966-1967. 

o.   The Village’s failure to assess major improvements from 1996-2004 has exacerbated the problems with a tax base that was already legally untenable due to the inequities which have developed since the last time there was a Village-wide reassessment in 1966-1967. 

            Based on the above findings, we have to conclude that the Village's assessment rolls have been irreparably distorted.  Since 1996 over 600 parcels of real property have been given permanent tax breaks on millions of dollars worth of capital improvements at the expense of those owners of parcels which were not improved during this secret tax abatement program.  In addition, going forward the resulting higher market prices on these improved, yet underassessed parcels, will inevitably skew the Equalization Rate for the Village and the Residential Assessment Ratio. 

            In order to remedy the inequities caused by this failure to properly assess capital improvements and by the passing of time since the last Village-wide revaluation, we believe that the Village Board of Trustees must immediately adopt a program to revaluate the assessments on all the residential and commercial properties in the Village and to overhaul the present system of Real Property Cards.  In adopting such a program we also believe that someone other than Mr. Balog should be given the job of running such a program.  Based on his record as Village Assessor since 1996, we believe Mr. Balog has lost all creditability. 

            Given the personal conflicts of interest of several members of the Board of Trustees with a program for a Village-wide reassessment, we are cognizant of the fact that there is probably little likelihood that the present members of the Village Board will be inclined to adopt such a program.  Accordingly, if within 30 days we do not hear from you in writing that the Board has adopted a Village-wide reassessment program for 2005, we will pursue whatever legal remedies are available for restoring the integrity and legality of the Village’s assessment roll.                                         

Very truly yours,

 

 Thomas C. Hutton

 Elisabeth S. Harding

  

 

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