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Joseph E. Seagram & Sons, Inc. v. Tax Commission of the City of New York

238 N.Y.S.2d 228, 18 A.D.2d 109, (1963)

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Joseph E. Seagram & Sons, Inc. v. Tax Commission of the City of New York

New York Supreme Court, Appellate Division

238 N.Y.S.2d 228, 18 A.D.2d 109, (1963)

Facts

Joseph E. Seagram & Sons, Inc. (Seagram) (plaintiff) owned a building located at 375 Park Avenue (the Seagram Building) in New York City. The Seagram Building was unlike typical buildings in several ways: it was popularly known by name, had notable architecture, and was built out of unusual materials. The Seagram Building was set back from the sidewalk, meaning that the building was not as large as it could have been. Seagram used the Seagram Building as an office and rented unused space to tenants. Further, the notable nature of the Seagram Building brought prestige to Seagram. The Tax Commission of the City of New York (the commission) (defendant) assessed the value of the Seagram Building for tax purposes. Seagram appealed, offering an alternate assessment method that was based on Seagram’s rental income and took various expenses into account. Seagram proposed that the Seagram Building was worth $17,802,000, much less than the $36,000,000 construction cost. The trial court rejected Seagram’s alternate assessment and affirmed the assessment made by the commission. Seagram appealed.

Rule of Law

Issue

Holding and Reasoning (Steuer, J.)

Concurrence (Breitel, J.)

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