New Jersey's Tax Exempt Property

BRIEF HISTORYGenerally, prior to 1900 New JerseyState Budget line item.In 1985 the New Jersey Tax
local tax assessors seldom entered a complete list ofAssessment Study Commission looked into the Tax
tax exempt property located within their municipalityExempt Property problem and determined that while
on their tax rolls. Why should they, nobody wouldexempt property owners paid a "ready and available
ever think about levying a property tax onfee" to their local water utility to use water up "on
governmental, educational, church or other propertydemand" and be billed for its usage those same
used for charitable purposes. It made little sense toexempt property owners did not pay their municipal
those early property tax assessors to spend thegovernments for their public work departments or
resources to find, list and value such tax exemptpolice departments to have those public servants and
property. Why, taxing government and other taxtheir equipment "ready and available" to meet the
exempt property owners that served fundamentallyneeds of the exempt property owners when
public rather than private interests would be justrequired.The Commission made estimates as to the
taking publics money from one pocket and putting itamount of revenue that could be raised Statewide if
in the other pocket, right?Tax exemption casessuch taxing authority was given to municipal
brought before the New Jersey Courts after 1900governments by the Sate and recommended that
show many questionable property tax exemptionthe Legislature adopt such a law. Of course the
claims were filed by not for profit entities. AssessorsLegislature acted swiftly to draft a legislative
found that tax exempt property owners organizedresolution stating that the Legislature had no
for charitable and religious purposes leased their taxknowledge of and in no way supported such a user
exempt property rights to other for profitfee on churches and other not for profit charitable
businesses. At the same time other educationaland educational institutions.LESSONS LEARNED AND
institutions went way beyond the charges set forthTHE FUTUREEncourage local tax assessors to remain
in their charter's provisions by including under their taxvigilant in granting tax exemptions to only those
exemption umbrella such questionable property usesproperty owners who meet the letter of the law. Do
as polo fields for the use of their students and othernot attempt to impose user fees on tax exempt
private polo teams. With increasing complaints aboutproperty during sunlight hours in Trenton. Partisan
the abuses of tax exempt claims some local taxLegislative staff should remind their legislators that
assessors began to assess certain questionablethe clergy can speak from the pulpit on Sunday
educational, charitable and church property ownersabout the foolish and wrong headed user fee
for property that was not being used strictly forproposals of legislators who suggest imposing user
their chartered tax exempt purposes.Of course,fees on churches and the November elections falls on
these tax exempt property owners complained toa Tuesday only two short days from the Sunday
their legislators in Trenton about the wrongs causedsermon.If history is any prediction of the future then
them by the local property tax assessor. TheirNew Jersey may see more State owned properties
government representatives in Trenton then startedlike the Garden State Art Center have its name
to provide some standards in the property tax lawleased out for a profit. Perhaps one day instead of
for the tax assessors to follow. So, for differentthe Atlantic City Expressway New Jersey will have
uses of exempt property, presumably based on thethe Trump Expressway or the Mack Truck Turnpike.
worthiness to society of a particular property's use,It is even possible that one day New Jersey will sell
the law specified different standards. School buildingsits Sate House to a large corporation to raise needed
for example had to be actually used for theirrevenues and then rent it back. Would that require
intended purpose, while buildings for the work ofmore friendly Sate treatment of the corporate
churches had to be actually and exclusively used forcommunity, else eviction could ensue? Perhaps it
religious purposes, etc. Then County Boards ofreally comes down to the public being vigilant watch
Taxation and the State Courts had to begin settlingdogs. Why not require the Division of Taxation to
disputes over what those terms meant in actualpost on its web page a listing of Tax Exempt
application.Today, the property tax exemption battleProperty, by municipality, by ownership and by
continues. Should your church be able to build a largepurpose? Property taxation is a battle, and the tax
building to lease to a For Profit Day Care Center andassessors in New Jersey need the support of the
with the rent money pay off the building's mortgage?public to enforce the letter of the law.A New Jersey
Does a private school need a golf course for golfersGovernor one day may sign a law permitting the sale,
who are not students when school is out so as tolease, or granting of naming rights on State Owned
defray the expense of the golf course? These areProperty to raise money for some worthwhile State
the questions that local tax assessors, the courts andpurpose. Such revenue could be used to pay off
the government in Trenton struggles with daily.GOLDState Debt so as to free up cash for property tax
MINE OR MINE FIELDPrior to the Cahill Tax Policyrelief. The payment streams from such activities
Commission in 1973 other Tax Commissions createdcould become a new source of annual State revenue.
by the Legislature had looked solely into the legalOnce the State government adopted this new
status of tax exempt property in New Jersey andfunding mechanism my guess is that the local
took extensive testimony concerning perceived taxmunicipal and county governments would follow suit
exempt property abuses. Nevertheless, little could besoon thereafter. If State and Local governments
done legislatively at that time because there was nokeep doing the same fiscal things over and over and
Statewide tabulation of Exempt Property values inhoping to find new sources of revenue they will
New Jersey and therefore the fiscal tax impactnever be able to fully serve their citizens.I also think it
locally of changes in the law could not be weighed bywould be all right for the State to sell certain State
the State Government decision makers.To remedyowned property, so long as that sale did not
that problem the Division of Taxation in 1971, at thejeopardize the future economic prosperity of the
request of the Cahill Tax Policy Commission took onState or threaten the future safety of its people. For
the job of collecting over 100,000 exempt propertiesexample, the sale of the New Jersey Turnpike or
listed by Local Tax Assessors on their local TaxGarden State Parkway would leave the business and
Exempt Lists. The submission of Governor Cahill's Taxpeople in New Jersey who depend on those vital
Policy Report to the legislature was delayed so thatarteries at the mercy of a profit driven corporation.
the Exempt Property Study could be completedHowever, the sale and lease back of a State
because it was thought that such a list could containwarehouse would free up cash to pay off State
the pot of gold needed to avert major new taxdebt that is eating into the State's ability to provide
increases to pay for property tax relief. The studyvital services and provide property tax relief. The
was finished and its results were reported in theState might even sell a State property and use part
ensuing Tax Policy Commission Report withof the proceeds to invest in other property that
recommendations that in large did not meet theholds the potential to increase substantially in value in
political and social needs of the day for a new sourcethe future. My point is that State asset and debt
of revenue for property tax relief.However, while nomanagement needs a higher viability than it now
new revenue source for property tax relief wasreceives.Biography: Gerald ‘Jerry' Dowgin "The
found because of the Exempt Property Study, theProperty Tax Doctor" and the author of the
large concentrations of exempt property found inHomeowner's Assessment Review Guide ( a former
certain cities and towns lead to the adoption of atax assessor worked in the field of public finance at
State Aid Program called the PILOT Program whichthe State and local levels in New Jersey for more
stood for "payments in lieu of taxes." In essence, thethan three decades until his retirement in 2001. As a
State made payments to municipalities at theSupervising Tax Analyst in the Office of Research
effective municipal purpose tax rate for certainand Statistics in the Division of Taxation in the New
properties owned by the State. Those Sate AidJersey Department of Treasury he worked principally
payments over the years were seldom fully fundedon local property tax issues. Then he joined the
according to the formula set forth in the law becauseOffice of Legislative Services (OLS) in 1983 and
the program had its pay out level reduced by a fixedserved as the Secretary to the New Jersey Property
percentage for many State Budget years. Then theTax Assessment Study Commission for four years.
PILOT program was incorporated into the COMPTRAWhile working in the OLS, Local Government Section
State aid program which in effect locked up both thehe researched, drafted, and estimated the cost of
property values used to calculate its funding alongthe Senior Property Tax Freeze Bill which was signed
with the local effective municipal purposes tax ratesonto law and worked on legislation that became law
used in the formula at a static level. That COMPTRAthat virtually stopped the tax assessment practice of
program consolidated more than a dozen State aid"Spot Assessments" in New Jersey that had treated
programs along with the PILOT program into onemany property taxpayers unfairly.