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Baldwin Yacht Basin, Inc. v. Board of Assessors

Citations: 89 A.D.3d 838; 932 N.Y.2d 375

Court: Appellate Division of the Supreme Court of the State of New York; November 8, 2011; New York; State Appellate Court

Narrative Opinion Summary

Petitioners sought to reclassify their real property from class four commercial to class one residential for tax years 2004/2005 through 2006/2007, based on a resolution from the Village of Freeport’s Board of Trustees that rezoned the property to “Marine Apartment-Boatel, Condominium and Cooperative District” and prohibited commercial use. However, the resolution required the execution and recording of a declaration of restrictions, which the petitioners did not establish was completed. As a result, they failed to make a prima facie case for the relief requested, referencing Matter of Raritan Dev. Corp. v Silva. Additionally, there was a factual dispute regarding whether the property was vacant, a necessary condition for the class one designation under RPTL 1802(1), as indicated in Matter of Richmond County Country Club v Tax Commn. of City of N.Y. Consequently, the Supreme Court correctly denied the petitioners’ motion for summary judgment upon reargument.

Legal Issues Addressed

Denial of Summary Judgment

Application: The Supreme Court correctly denied the petitioners' motion for summary judgment upon reargument due to unresolved factual issues and lack of prima facie evidence.

Reasoning: Consequently, the Supreme Court correctly denied the petitioners’ motion for summary judgment upon reargument.

Prima Facie Case for Relief

Application: The petitioners failed to make a prima facie case for the relief requested due to lack of evidence of the completed declaration of restrictions.

Reasoning: As a result, they failed to make a prima facie case for the relief requested, referencing Matter of Raritan Dev. Corp. v Silva.

Reclassification of Property for Tax Purposes

Application: Petitioners sought to reclassify their property from commercial to residential based on a zoning resolution, but failed to meet the requirements for such reclassification.

Reasoning: Petitioners sought to reclassify their real property from class four commercial to class one residential for tax years 2004/2005 through 2006/2007, based on a resolution from the Village of Freeport’s Board of Trustees that rezoned the property to 'Marine Apartment-Boatel, Condominium and Cooperative District' and prohibited commercial use.

Requirement of Executed Declaration of Restrictions

Application: Petitioners were required to execute and record a declaration of restrictions to finalize the rezoning, which they failed to establish was completed.

Reasoning: However, the resolution required the execution and recording of a declaration of restrictions, which the petitioners did not establish was completed.

Vacancy Requirement for Class One Designation

Application: There was a factual dispute about whether the property was vacant, which is a necessary condition for class one residential designation.

Reasoning: Additionally, there was a factual dispute regarding whether the property was vacant, a necessary condition for the class one designation under RPTL 1802(1), as indicated in Matter of Richmond County Country Club v Tax Commn. of City of N.Y.