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

200 N.E.2d 447, 251 N.Y.S.2d 460, 14 N.Y.2d 314 (1964)

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

New York Court of Appeals
200 N.E.2d 447, 251 N.Y.S.2d 460, 14 N.Y.2d 314 (1964)

  • Written by Heather Whittemore, JD

Facts

Joseph E. Seagram & Sons, Inc. (Seagram) (plaintiff) owned a building located at 375 Park Avenue, commonly referred to as the Seagram Building, in New York City. The Seagram Building cost $36,000,000 to build and was used by Seagram as an office and a source of rental income. The Tax Commission of the City of New York (the commission) (defendant) assessed the value of the Seagram Building for property-tax purposes. Seagram challenged the assessment in New York state court, arguing that the value of the Seagram Building should be determined through a capitalization-of-net-income approach by taking into account the rental income Seagram earned from its tenants. The trial court upheld the commission’s assessment. The New York Supreme Court, Appellate Division affirmed the trial court, holding that given the Seagram Building’s unusual structure and the prestige attached to it, the rental value of the property did not accurately reflect the building’s value. Seagram appealed.

Rule of Law

Issue

Holding and Reasoning (Desmond, C.J.)

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Casebooks

State and Local Taxation

Key Terms