Compared to the rest of the world’s countries that rely on some form of property tax, the United States is far and away the most fragmented of systems (and I use the word “systems” quite loosely).  Every state and territory in the Nation is governed by a different legal code, none of which has bearing upon another.  The property tax law of Connecticut, for example, is meaningless in New York, and likewise in New Jersey.  The administration of assessments and their review often bare only the most general resemblance from one state to another, and “market value” in one may mean something different in others.  The most that the U.S. has to offer that looks like “uniformity” is the suggested guidelines produced by the International Association of Assessing Officers (IAAO); while these guidelines are the high water mark of good assessment practice, they are only occasionally followed and are not binding.  Running a so-called national property tax practice is a nightmare for consulting firms, which must effectively manage widely varying deadlines, forms, ratios, valuation nuances, review processes, and so on without ever dropping the ball.

That’s the birds-eye view of managing property taxes nationally.  But then there is New York State.  The most fragmented of the fragmented.  Most practitioners who operate in New York will limit themselves to a fairly small geographic area within the state, perhaps just three or four of the sixty-two counties at most.  New York City practice is an entirely different animal than anything north of the City, with different forms, review procedures, and deadlines than the rest of the State.  Okay, so New York City is different: probably no great surprise.  But, then, Westchester County and some of the others in the Hudson Valley often operate differently than their fellow counties to the north and west.  Courts view the cases distinctly differently depending on what part of the state the property is located.  And, with only a few exceptions, every city, town, and village has its own assessor, its own assessment ratio, its own board of assessment review, its own tax rates, its own tax collector, its own property valuation date, and its own deadlines.  While it’s true there’s one state Real Property Tax Law, you’d better understand local interpretations of that law and local custom and procedure for moving a case through the courts.  The pronouncements of an upstate or western New York appellate court (even) are only “persuasive” to a court located elsewhere in New York unless there’s nothing else upon which to rely.  Only about a third of New York’s municipalities have conducted a fairly recent revaluation, with the decision being left up to the local town board or city council, and often viewed as an act of political suicide.  Very little that the State’s “Office of Real Property Services” has to say is taken as more than a suggestion, with most guidance coming in the form of “Opinions of Counsel” which are, as they state, merely opinions. 

Despite Albany’s annual rail against high property taxes while stuffing unfunded mandates down the throats of the local jurisdictions it criticizes, our state legislators are just as fearful of losing their jobs as their municipal counterparts.  Many bandaids are applied to the New York property tax system by the legislature, but virtually nothing has been done to streamline the administration and review of property taxes in New York.  Other states provide compelling examples of better and more centralized control and administration: Connecticut, Massachusetts, Oregon, to name a few.  New York State remains more fragmented, confusing, draconian, and inequitable than ever, so it should be no wonder that the property tax bill here is among the highest in the nation if not the world.