Hunterdon Medical Center: Earlier Rental Income Made the Assessor’s Requested Year Matter

A medical building earned rent during the historical year covered by an assessor’s request, even though its occupancy later changed. That earlier income mattered in Hunterdon Medical Center v. Township of Raritan, No. 005101-2025 (N.J. Tax Ct. Oct. 28, 2026). The New Jersey Tax Court limited the owner’s 2025 assessment appeal after the owner failed to answer the request for 2023 income and expense information. This unpublished New Jersey decision, posted October 29, applies New Jersey’s Chapter 91 procedure. Hunterdon Medical Center, opinion at 1.

The requested year included a rent-paying tenant

The medical center owned a medical office building it shared with a plastic surgeon and SAFE, a nonprofit agency. The surgeon paid rent during the early part of 2023 before leaving. SAFE paid nominal annual rent of $1 under a verbal agreement. The owner also occupied part of the property.

The assessor requested calendar-year 2023 income and expense information by regular mail on May 6, 2024, and again by certified mail on October 29. The owner answered neither request. When it challenged the 2025 assessment, the township sought to limit the appeal under N.J.S.A. 54:4-34. Hunterdon Medical Center, opinion at 2–3.

The owner relied on a different date

The owner argued that the building was not income-producing on October 1, 2024, the pre-tax assessment date. The dispute therefore required the court to identify the relevant period: A single valuation date or the historical operating period covered by the request.

The court chose the requested historical period. Valuation can depend on earlier operations, and a single-date test could exclude property temporarily vacant on that date despite its income-producing history. Following Alfred Conhagen, Inc. v. Borough of South Plainfield, 16 N.J. Tax 470 (App. Div. 1997), it treated the surgeon’s paid tenancy during 2023 as sufficient. Hunterdon Medical Center, opinion at 6–8.

Failure to answer narrowed the appeal

Chapter 91 requires a timely response to a qualifying certified-mail request concerning income-producing property. The opinion describes a 45-day response period. Failure to supply the information limits the taxpayer to the narrower reasonableness review recognized in Ocean Pines, Ltd. v. Borough of Point Pleasant, 112 N.J. 1 (1988), rather than an unrestricted valuation appeal. Hunterdon Medical Center, opinion at 4.

That distinction mattered because the owner’s position about present occupancy did not answer the request for the prior year. The court granted the township’s motion to limit the appeal. It had no need to resolve whether SAFE’s nominal $1 rent independently made the property income-producing: The surgeon’s rent already supplied that basis. Hunterdon Medical Center, opinion at 9.

The practical lesson is to match the records to the request

For a property that moves between rented, vacant and owner-occupied use, preserve a dated occupancy history, leases, rent receipts and termination records. Read the period stated in the assessor’s actual request before deciding that current occupancy answers it.

The consequence here comes from New Jersey law. California owners need the California request and applicable statutes reviewed separately; the companion Insight explains that distinction. For either review, bring the complete request, delivery evidence, response history and records for the requested period. Those documents reveal whether the disagreement concerns the property’s history, the scope of the request or a missed response.