160 CHUBB PROPERTIES, LLC v. TOWNSHIP OF LYNDHURST

Annotate this Case

(NOTE: The status of this decision is Published.)

NOT FOR PUBLICATION WITHOUT APPROVAL OF
THE TAX COURT COMMITTEE ON OPINIONS

160 CHUBB PROPERTIES, LLC,
TAX COURT OF NEW JERSEY
Plaintiff, DOCKET NOS. 002442-2014
006305-2015
v.
Approved for Publication
TOWNSHIP OF LYNDHURST, In the New Jersey
Tax Court Reports
Defendant.

Decided: December 14, 2018

Joseph G. Ragno and Robert J. Guanci for plaintiff
(Waters, McPherson, McNeill, P.C., attorneys).

Kenneth A. Porro for defendant
(Chasan, Lamparello, Mallon & Cappuzzo, P.C., attorneys).

ORSEN, J.T.C.

This opinion constitutes the court’s decision with respect to plaintiff, 160 Chubb

Properties, LLC’s (“Chubb”) motion for relief under N.J.S.A. 54:51A-8 (hereinafter the “Freeze

Act”) for the 2017 tax year based on the settled and adjudged assessment for tax year 2015.

Defendant, Township of Lyndhurst (“Lyndhurst”), opposes the motion, and asserts that the

settlement agreement between the parties limits Freeze Act relief to tax year 2016. Lyndhurst

further claims that improvements were made to the property after 2015, which resulted in a change

in value that precludes application of the Freeze Act.

For the reasons stated more fully below, the court concludes that (1) Chubb did not waive

Freeze Act protection for the 2017 tax year; and (2) Lyndhurst is not entitled to a plenary hearing

on the applicability of the Freeze Act, since it has not made a prima facie showing that a substantial

*
and meaningful change in value occurred between base year 2015 and freeze year 2017.

Accordingly, the Freeze Act applies, and the 2017 assessment should be reduced to the amount

reflected in the judgment for tax year 2015.

FACTS

The following findings of fact and conclusions of law are based on the certifications and

exhibits submitted in support of the parties’ pleadings.

On December 3, 2013, Chubb purchased a multi-tenanted office building located at 160

Chubb Avenue, Lyndhurst, New Jersey, designated as Block 231, Lot 3 on the local tax map

(“subject property”), for $10,300,000.

Chubb filed property tax appeals for the 2014 and 2015 tax years. For each tax year, the

subject property’s assessment was $16,250,000. Chubb alleged that the assessments were in

excess of the true value of the subject property and that Lyndhurst assessed the property in an

arbitrary, unreasonable, unequal, and discriminatory manner when compared to assessments of

other properties within the taxing district.

During 2014 and 2015, Chubb obtained construction permits totaling $355,100 1 for the

subject property on the following dates:

1. March 24, 2014 – building and electrical rehabilitation work in the
amount of $6,900;
2. April 16, 2015 – building, electrical, plumbing, and fire protection
rehabilitation work in the amount of $206,700;
3. April 27, 2015 – building electrical, and fire protection rehabilitation
work in the amount of $20,000;
4. May 13, 2015 – electrical rehabilitation work in the amount of $75,000;
and
5. September 17, 2015 – building, electrical, plumbing, and fire protection
work in the amount of $46,500.

1
The amounts reflected on the permits were the estimated cost of the work to be done.
2
On November 5, 2015, after the permits were issued, the parties were able to resolve the

tax appeals and filed a Stipulation of Settlement for the 2014 and 2015 tax years. The Stipulation

of Settlement reduced the assessments for both tax years as follows:

Original Settled
Assessment Assessment
2014 - 2015 2014 - 2015
Land $11,286,000 $11,286,000
Improvements $ 4,964,000 $ 1,714,000
Total $16,250,000 $13,000,000

With respect to the Freeze Act, Paragraph 4 of the Stipulation of Settlement included the

following language:

The parties agree that there has been no change in value or
municipal-wide revaluation or reassessment adopted for the tax year
2016, and therefore agree that the provisions of [ N.J.S.A.] 54:51A-
8 (Freeze Act) shall be applicable to and a final disposition of this
case and the entire controversy and of any actions pending or
hereafter instituted by the parties concerning the assessment of the
property referred to herein for said Freeze Act year. No Freeze Act
year shall be the basis for application of the Freeze Act for any
subsequent year.

The court entered judgments on December 18, 2015 for the 2014 tax year and December

4, 2015 for the 2015 tax year, in accordance with the agreed to assessment of $13,000,000. Based

on the language in paragraph 4 of the Stipulation of Settlement, the Freeze Act was expressly

adopted.

Although the 2015 tax year judgment was the “base year” for 2016 Freeze Act relief,

Lyndhurst’s tax assessor continued to assess the subject property at $16,250,000 for the 2016 tax

year. The parties resolved this matter during the summer of 2016, reducing the 2016 assessment

to the agreed $13,000,000 assessment. For tax year 2017, the assessor continued to assess the

3
subject property at $16,250,000, despite having resolved application of the Freeze Act for tax year

2016 prior to the October 1, 2016 valuation date. 2

Chubb sold the subject property on November 17, 2016 to its current owner, CCC NJ

Owner, LLC, for $20,025,000. Thereafter, Chubb filed a motion for entry of judgment applying

the Freeze Act to the 2017 tax year based on the 2015 tax year judgment.

Given the proximity of the 2016 tax year assessment date at the time of the settlement,

Chubb reasoned that the Stipulation of Settlement included normal language as to the applicability

of the Freeze Act for the 2016 tax year. Chubb further noted that the Stipulation of Settlement did

not address invocation of the Freeze Act for the 2017 tax year, instead maintaining that the parties

were not in a position when the Stipulation of Settlement was executed to make the required

recitations to invoke the Freeze Act for the 2017 tax year, that “no change in value” and “no

revaluation or assessment” was contemplated for tax year 2017. Chubb additionally argued that a

waiver of the Freeze Act for the 2017 tax year was not a term of the Stipulation of Settlement.

Lyndhurst opposed Chubb’s Freeze Act application, claiming in its response that Chubb

was trying to circumvent the clear intent of the settlement agreement by arguing that (1) the

settlement reducing the assessments was based on Chubb’s representation that the subject property

was substantially unoccupied at the time of Chubb’s purchase, and also needed substantial

improvements; and (2) the parties had agreed that the Freeze Act would only apply to 2016, thus

Chubb waived its application for 2017. Lyndhurst additionally emphasized that after the alleged

improvements were made to the subject property, Chubb sold the property for $20,025,000, which

is almost double the 2013 purchase price. In support, Lyndhurst’s assessor certified that the

2
For reference, the Chapter 123 average ratio for the municipality with respect to tax year 2017
is 85.10%.
4
“[s]ubstantial building improvements along with the tenant occupancy undoubtedly increased the

value of the property as it was sold for $20,025,000 on November 17, 2016.” Accordingly,

Lyndhurst requested a plenary hearing with an opportunity for further discovery to resolve these

matters.

In reply, Chubb submitted a certification by the subject property’s manager who claimed,

in part:
3. At no time since the time of the purchase of the property by 160
Chubb Properties, LLC on December 3[,] 2013 has the subject
property been less than 75% occupied.

4. I have reviewed the Construction Permits dated March 24, 2014,
April 16, 2015, April 27, 2015, May 13, 2015 and [September] 17,
2015 which were attached to the Certification of Denis J. McGuire,
CTA, Tax Assessor for the Township of Lyndhurst, for construction
on the building and electrical work; building, electrical, plumbing,
and fire protection work; and electrical rehabilitation work. The
work described in the permits, in each case, represents tenant fit-out
work and capital repairs, replacements and rehabilitation of building
systems and improvements in the ordinary course of operating a
multi-tenanted office building.

Chubb reiterated that waiver of the Freeze Act for the 2017 tax year was never discussed

at the time of settlement or during execution of the Stipulation of Settlement. Chubb also asserted

that Lyndhurst failed to make a prima facie showing that Freeze Act relief is unavailable, as the

issued construction permits do not rise to the level of evidentiary support needed to show a

substantial and meaningful increase in value of the subject property. Chubb additionally pointed

out that Lyndhurst failed to utilize the Chapter 91 “arsenal of devices” at a tax assessor’s disposal

to investigate occupancy status, relying on nothing more than the tax assessor’s certification to

support its claim that the subject property was substantially unoccupied when Chubb purchased

the property in 2013.

5
ANALYSIS

I. Procedural Requirements

The court begins its analysis with a review of the Freeze Act, which does not contain any

limitations period to file a motion to enforce its provisions. See N.J.S.A. 54:51A-8; R. 8:7(d). The

Freeze Act specifically provides, in part:

Where a judgment not subject to further appeal has been rendered
by the Tax Court involving real property, the judgment shall be
conclusive and binding upon the municipal assessor and the taxing
district, parties to the proceeding, for the assessment year and for the
two assessment years succeeding the assessment year covered by the
final judgment, except as to changes in the value of the property
occurring after the assessment date. The conclusive and binding
effect of the judgment shall terminate with the tax year immediately
preceding the year in which a program for a complete revaluation or
complete reassessment of all real property within the district has
been put into effect.
[N.J.S.A. 54:51A-8.]

The historical background of changes to the Freeze Act is relevant to clarify the procedural

posture of Lyndhurst’s challenge to the freeze protections sought by Chubb. Prior to 1999, a taxing

district had “to file a complaint seeking relief from the base year assessment” to prevent application

of the Freeze Act on grounds of an alleged change in value. AVR Realty Co. v. Cranford Twp.

(“AVR I”), 294 N.J. Super. 294, 299 (App. Div. 1996), cert. denied, 148 N.J. 460 (1997).

However, in 1999 this procedural requirement was eliminated when the Freeze Act was amended. 3

Our courts have construed this deletion, “as relieving the municipality of the obligation to file a

Freeze Act avoidance complaint when the base year judgment has been entered before the

assessment date for the freeze year, as previously required . . . .” Entenmann’s Inc. v. Totowa

3
The following language was deleted from N.J.S.A. 54:51A-8, “Where those changes are alleged,
the complaint shall specifically set forth the nature of the changes relied upon as the basis for the
appeal.” L. 1999, c. 208, § 16.
6
Borough, 19 N.J. Tax 505, 520 (Tax 2001), aff’d, 21 N.J. Tax 182 (App. Div. 2003). A municipal

defendant is therefore allowed to resist a plaintiff’s Freeze Act application without having filed a

Freeze Act avoidance complaint. Id. at 521. However, the procedural change still requires the

taxing district to make a prima facie showing of a change in value in order to obtain a plenary

hearing. Ibid.

In the instant matter, the 2015 base year judgment was entered on December 4, 2015. Such

judgment was entered before the October 1, 2016 assessment date for the 2017 tax year at issue.

Prior to the 1999 amendment, the municipality was required to file a Freeze Act avoidance

complaint to obtain relief. However, as this requirement is no longer applicable, the court will

entertain Lyndhurst’s opposition to Chubb’s motion for Freeze Act relief.

II. Application of Freeze Act

The Freeze Act protects a taxpayer by freezing the assessment for two years following

entry of a final judgment by the Tax Court for a particular year. See N.J.S.A. 54:51A-8; R. 8:7(d).

The Freeze Act applies equally to judgments issued pursuant to settlement negotiations as to

judgments following a full trial on the merits. S. Plainfield Borough. v. Kentile Floors, Inc., 4 N.J.

Tax 1 (Tax 1981), aff’d, 186 N.J. Super. 399 (App. Div. 1982), aff’d, 92 N.J. 483 (1983). Since

the Freeze Act is self-executing, the taxpayer does not need to file a tax appeal to obtain protection

from repetitive litigation concerning assessments “not related to or justified by any changes

increasing [a property’s] market value, and resulting in harassment of the taxpayer . . . .” See AVR

Realty Co. v. Cranford Twp. (“AVR II”), 316 N.J. Super. 401, 405-06 (App. Div. 1998), certif.

denied, 160 N.J. 476 (1999) (quoting Newark v. Fischer, 8 N.J. 191, 200 (1951)); Hackensack City

v. Bergen Cty., 405 N.J. Super. 235, 247 (App. Div. 2009). The tax assessor is further obligated

to conform assessments for the freeze years to the judgment, if the judgment for the base year was

7
entered prior to the assessment date for the applicable Freeze Act years. AVR II, 316 N.J. Super.

at 406. Inclusion of the Freeze Act’s applicability in a settlement is not a prerequisite for its

operation. Kentile Floors, Inc., 4 N.J. Tax at 10. As such, Freeze Act relief can only be avoided

if affirmatively waived by the taxpayer or if a statutory exception is present.

A. Waiver of Freeze Act

The Freeze Act provisions will apply unless the taxpayer affirmatively waives application.

Ritchie & Page Distrib. Co., Inc. v. City of Trenton, 29 N.J. Tax 538, 543 (Tax 2016) (citing

Zisapel v. Paramus Borough, 20 N.J. Tax 209, 212 & n.1 (Tax 2002)); see also Kentile Floors,

Inc., 92 N.J. at 489. Our courts have traditionally defined waiver as “the voluntary relinquishment

of a known right evidenced by a clear, unequivocal and decisive act from which an intention to

relinquish the right can be based.” Scibek v. Longette, 339 N.J. Super. 72, 82 (App. Div. 2001)

(citing Country Chevrolet v. N. Brunswick Planning Bd., 190 N.J. Super. 376, 380 (App. Div.

1983)). A taxpayer’s waiver of Freeze Act protection must necessarily involve the intentional

relinquishment of a “known right” evidenced by “a clear, unequivocal, and decisive act” by the

taxpayer. While an intention to waive freeze protection by a party does not need to be expressly

stated, it must be demonstrated that the party had full knowledge of its legal rights and that the

relinquishment of its rights was deliberate and intentional. Id. at 83. Therefore, one claiming an

implied waiver must show intentional relinquishment of a known legal right. Ibid.; see also

Merchants Indem. Corp. v. Eggleston, 68 N.J. Super. 235, 254 (App. Div. 1961), aff’d, 37 N.J.
114 (1962) (explaining that a waiver by a party may derive from a state of facts exhibiting full

knowledge of the circumstances producing a right and continuing indifference in exercising that

right). Additionally, the municipality’s intent as to whether the Freeze Act is waived is irrelevant.

8
Kentile Floors, Inc., 92 N.J. at 491 (rejecting the Borough’s contention that it did not intend to

bind itself to a freeze act assessment).

Here, Lyndhurst asserted that at the time the Stipulation of Settlement was executed it

believed that the proposed work to be done on the subject property would not be completed by

October 1, 2015 and therefore, the parties agreed that the Freeze Act would only be applicable to

the 2016 tax year and was waived for the 2017 tax year. To the contrary, Chubb argued that Freeze

Act application was not waived for the 2017 tax year because it was not discussed by the parties

at the time of settlement or execution of the Stipulation of Settlement.

As memorialized in Paragraph 4 of the Stipulation of Settlement, both parties agreed that

the Freeze Act would be applicable to the 2016 tax year. Moreover, since the Freeze Act is self-

executing, it is not necessary to expressly invoke its application. The court focuses instead on

whether a taxpayer deliberately and intentionally waived Freeze Act protection. Here, the court

observes that there is no express mention of the term waiver, nor is there any indication that Chubb

requested or agreed to waive Freeze Act protection for the 2017 tax year. Notwithstanding the

lack of written waiver by Chubb, Lyndhurst has not presented support for any action taken by

Chubb implying an intentional surrender of Freeze Act protection or continued indifference in

exercising its Freeze Act protection rights.

The court does not construe Paragraph 4 of the Stipulation of Settlement as a waiver of the

Freeze Act. Accordingly, the court finds that Chubb did not waive its right to enforce Freeze Act

relief for the 2017 tax year.

B. Statutory Exceptions to the Freeze Act

Since the court finds that Chubb did not expressly or intentionally waive application of the

Freeze Act for the 2017 tax year, the court must evaluate whether Chubb is statutorily barred from

9
invoking Freeze Act protection. The legislative purpose of the Freeze Act is to prevent the

“repeated yearly increases in the assessed value of property, not related to or justified by any

changes increasing its market value and resulting in harassment of the taxpayer, subjecting him to

the trouble and expense of annual appeals to the county tax board.” AVR II, 316 N.J. Super. at
405-06 (quoting Newark v. Fischer, 8 N.J. 191, 200 (1951)). However, the Freeze Act is not

without its limitations.

Freeze Act relief is not available (1) when the taxing authority demonstrates circumstances

occurring after the base year assessment date that result in an increase in the value of the property,

or (2) when the taxing authority implements a revaluation program affecting all property in the tax

district. N.J.S.A. 54:51A-8. Here, no allegation is made of a district-wide revaluation or

reassessment of all real property.

To demonstrate circumstances that result in an increase in value of the property, the

municipality “must make a prima facie showing that there was a change in . . . value between the

assessment dates for the base year and freeze years” and further that “(1) the change in value

result[ed] from an internal or external change; (2) the change materialized after the assessing date

of the base year; and (3) the change substantially and meaningfully increased the value of the

property.” Coastal Eagle Point Oil Co. v. Twp. of W. Deptford, 353 N.J. Super. 212, 218 (App.

Div. 2002). Upon such a showing, the court will hold a plenary hearing to determine Freeze Act

applicability. Id.; see also Rockstone Grp. v. Lakewood Twp., 18 N.J. Tax 117, 121 (Tax 1999)

(“If the municipality has provided sufficient evidence to raise a debatable question as to whether

there has been a change in value as such term is used in N.J.S.A. 54:51A-8, it is entitled to a

plenary hearing.”). However, if the municipality fails to make a prima facie showing, the taxpayer

is entitled to summary relief. Coastal Eagle Point Oil Co., 353 N.J. Super. at 220.

10
Our courts have consistently found that internal changes consist of capital improvements

that substantially and meaningfully increase the value of the subject property, while external

changes consist of extreme economic changes or zoning changes in close proximity to the property

that increase its value. See id. at 219 (examples of internal changes consist of physical

refurbishments or additions such as added wings or added floors); Cumberland Arms Assocs. v.

Burlington Twp., 10 N.J. Tax 255, 263 (Tax 1988) (concluding that the 1976 amendment to our

State’s constitution permitting casino gambling in Atlantic City is an example of an external

change that increased property values). However, not just any change to a property can be used to

overcome freeze protection, as this would render the Freeze Act meaningless. Mediterannean

House v. Fort Lee Borough, 7 N.J. Tax 528, 535 (Tax 1985).

1. Occupancy of the Subject Property

The first of the two submitted proofs in this case consists of certifications made by the

subject property’s manager and Lyndhurst’s tax assessor regarding occupancy of the subject

property.

According to Lyndhurst’s tax assessor, “[b]ased upon [Chubb’s] representation, the

building in 2013 was substantially unoccupied at [the] time of the sale and also needed substantial

improvements.” Conversely, the manager certified that the subject property had never been less

than 75 percent occupied during Chubb’s ownership. Here, Lyndhurst bears the burden of making

a prima facie showing to obtain a hearing on its claim of change in value. Bare allegations that

the subject property was substantially unoccupied without further evidentiary support as to either

an increased occupancy, or that such increased occupancy concurrently increased the subject

property’s value, are unavailing. See Ritchie & Page Distrib. Co., Inc., 29 N.J. Tax at 545 (citing

Entenmann’s Inc., 19 N.J. Tax at 514-15). See also Union Minerals and Alloys Corp. v. Town of

11
Kearny, 11 N.J. Tax 280, 285 (Tax 1990), aff’d, 13 N.J. Tax 114 (App. Div. 1992) (determining

that “mere increase[s] in tenant occupancy unrelated to a change in market conditions does not

result in the change in value contemplated by the freeze act.”). Such an “argument presupposes

that the more tenants there are in a building, the higher the building's value.” Ibid. However, as

that court aptly pointed out, “a critical aspect of the freeze act [is] . . . that the value to which the

statute refers is value for tax purposes.” Ibid.

In this case, Lyndhurst has made unsubstantiated assertions that, “[b]ased upon Plaintiff’s

representation,” the subject property was substantially unoccupied at the time of Chubb’s purchase

without providing any corroborating evidence. In accordance with Ritchie & Page Distrib. Co.,

Inc. and Union Minerals and Alloys Corp., the court cannot find that bare allegations of increases

in tenant occupancy, unrelated to changes in market conditions, are sufficient as a matter of law to

demonstrate a substantial change in value. 4

The court finds that Lyndhurst’s heavy reliance on the tax assessor’s certification

concerning increased occupancy of the subject property, without supporting evidence, is

insufficient as a matter of law to demonstrate a substantial and meaningful change in value.

2. Construction Permits

The second of the submitted proofs in this case consists of five construction permits. As a

preliminary matter, the court recognizes that “physical change alone is not proof that a substantial

4
Chubb additionally pointed out that Lyndhurst offers nothing to support its claim that the
property was substantially unoccupied at the time of the 2013 purchase, highlighting that
Lyndhurst failed to utilize the Chapter 91, N.J.S.A. 54:4-34, “arsenal of devices” that are at the tax
assessor’s disposal for investigating occupancy of a property. However, in the hypothetical
situation where Lyndhurst had availed itself of the Chapter 91 toolbox, the court would not
automatically find for it if Chubb decided not to comply with the Chapter 91 requests. See Ritchie
& Page Distrib. Co., Inc. 29 N.J. Tax at 545 (the Freeze Act denies relief only under specific
circumstances, none of which is failure to respond to a Chapter 91 request).
12
and meaningful change in the market value of the property has occurred.” 2nd Roc-Jersey Assocs.

v. Morristown Town, 11 N.J. Tax 45, 52 (Tax 1990). For purposes of defeating a Freeze Act

application, the municipality must show that the change in value of the property was substantial

and meaningful by a comparison of the property’s value before-and-after any physical changes.

Ibid.

The construction permits reveal that the proposed work to be done on the subject property

was related to tenant fit-out work and capital repairs, in addition to replacements and rehabilitation

of building systems, and improvements made in the ordinary course of operation. Chubb argues

that the $355,100 cost of improvements set forth in the permits is a small fraction of the sales price,

thus it does not evidence a substantial increase in value of the subject property. While Lyndhurst

emphasizes that Chubb sold the property in 2016 for double the original purchase price, our court

has found that, “the selling price of real property involved in a judicial determination of its

assessable value is a 'guiding indicium’ of fair value and ordinarily is merely evidential.” See

Harrison Realty Corp. v. Harrison Town, 16 N.J. Tax 375, 381 (Tax 1997), aff’d, 17 N.J. Tax 174

(App. Div. 1997). See also Mediterannean House, 7 N.J. Tax at 537-38 (where the court

determined that a better approach in evaluating changes in property value is analyzing the market

activities in a specific area).

Here, the permits provided by the parties include a breakdown of work done and items

added to the subject property. Chubb’s manager certified that the work set forth in the permits

was the rehabilitation of the subject property’s electrical, plumbing, and fire protection systems.

This court has similarly found that “the mere retrofitting, upgrading, or remediation of deferred

maintenance does not constitute . . . an improvement,” for purposes of imposing an added

assessment. Otelsberg v. Bloomfield Twp., 18 N.J. Tax 243, 251-52 (Tax 1999). In Fifth Roc

13
Jersey Assoc., L.L.C. v. Town of Morristown, the court found that even after extensive discovery

and plenary hearing, renovations to the guest rooms, lobby ballroom, bar, and elevators, in addition

to the installation of eighteen smoke detectors and six heat detectors, did not qualify as

improvements, but rather as retrofitting, upgrading, or remediation of deferred maintenance which

did not warrant additional assessments or denial of relief under the Freeze Act. 26 N.J. Tax 212,

227-28 (Tax 2012). Although addressing improvements to a building under the added assessment

statute, N.J.S.A. 54:4-63.2 to -63.3, the reasoning and conclusions in Fifth Roc provide guidance

in determining the type of work that qualifies as substantial and meaningful that prima facie

establish an increase in value as opposed to mere rehabilitation and retrofitting.

Since sales price is merely a 'guiding indicium’ of value, it does not establish, per se, a

change in value for purposes of the Freeze Act. Lyndhurst must first demonstrate that a substantial

and meaningful change in value has occurred before the court will grant a request for a plenary

hearing. Here, Lyndhurst has not provided any evidence in this regard. Rather, it asks the court

to grant a plenary hearing based on bare unsupported allegations that the work performed under

the permits impliedly constituted more than just retrofitting, upgrading, or remediation of deferred

maintenance, based on the November 2016 sale price of the subject property. Without more, the

court finds that Lyndhurst’s reliance on the construction permits fails to demonstrate a substantial

and meaningful change in value of the subject property to warrant denial of Chubb’s Freeze Act

application.

CONCLUSION

For the reasons set forth hereinabove, the court concludes that Chubb did not waive its

Freeze Act rights for the 2017 tax year. Additionally, as Lyndhurst has not made a prima facie

showing that a substantial and meaningful change in value occurred, it is not entitled to a plenary

14
hearing on the applicability of the Freeze Act. Therefore, the 2015 tax appeal judgment is binding

on Lyndhurst for the 2017 tax year. Chubb’s Freeze Act application is granted.

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