"Night of the living tax break": Forest City Ratner among big beneficiaries of canceled but still operating ICIP

The watchdog site New York World yesterday published Night of the living tax break:

Five years after state lawmakers killed a corporate property tax exemption that had outlived its original purpose, it’s still stalking New York City’s finances, to the tune of more than $650 million this year.
...Other windfalls went to the headquarters of News Corporation — the owner of the New York Post — whose tax bill is cut by some $2.2 million this year, and Manhattan’s East River Plaza mall, a project co-owned by real estate giant Forest City Ratner, which got two breaks totaling $8.1 million.
...These are among the more than 7,000 properties that continue to receive abatements on property taxes under the city’s Industrial and Commercial Incentive Program, or ICIP, first launched in the 1980s to encourage businesses to locate or remain in New York City.
That program was open to a wide array of business that built or made improvements to their properties. It expired in 2008, amid widespread criticism that it was too generous. But any company that had successfully applied for the break before then would continue to get it — for as long as 25 years.
In fact, the cost of the tax break to the city has swelled since it supposedly died, rising from $512 million in 2008 to a peak of $682 million in 2012. That’s because the properties, as a condition of the tax break, have undergone improvements that increase their value over time.

Forest City's totals

Forest City Ratner has three properties on the top 20 list: Forest City Myrtle Associates at 115 Myrtle Avenue (MetroTech), with a $5.9 million tax abatement; Tiago Holdings (a co-venture with Blumenfeld Development Group), with $8.1 million granted; and FC Queens Place, with $2.6 million from the Queens Place mall, of which Forest City sold 49% in 2011.

But that's not all. According to the database provided The New York World by Good Jobs New York, there are numerous Forest City properties (mostly retail properties, with that 49% share sold in 2011) on the list.

Note that the first column below is the tax abatement, the second the taxes paid, and that the abatement does not precisely match the number in the chart above. That's because the chart shows the 2013 abatements, while the downloaded info covers 2012.

What it means

As the New York World's Nathaniel Herz reported, the program "effectively reallocates the commercial property tax burden to other property tax payers,” said James Parrott of the Fiscal Policy Institute.

Former city official Alair Townsend described the tax incentive as a tactic launched by the struggling city to keep businesses in the late 1970s and early 1980s from moving to New Jersey or other suburbs:

The idea was to encourage job-producing construction — either new buildings, or renovations — by not immediately taxing owners on improvements to their property. Projects qualified on an “as-of-right basis,” not based on need — meaning that as long as they met a certain set of criteria based on location, use, and size of investment, they’d get the subsidy.
Following scathing audits of the program, the Bloomberg administration took a hard look at what all the tax breaks were paying for. A 2007 study by the city’s Economic Development Corporation revealed that more than 75 percent of participating projects — which cost some $2.8 billion in subsidies — would have gone ahead even without the ICIP exemption.

As with the 421-a tax relief program for market-rate construction, the program was not tinkered with until the city had clearly recovered. The NY World reports:

“This is an example of an as-of-right program run amok,” said Bettina Damiani, project director for the advocacy group Good Jobs New York, which supplied the New York World with ICIP data acquired from the Department of Finance through a public records request. (Download the data in CSV format.) “When you start subsidizing midtown retail and midtown office buildings, things have clearly gone awry.”
The exemptions also extend to several large Queens malls, where visitors and workers were surprised to hear about the value of the tax breaks being extended to corporate owners.
...After ICIP’s demise in 2008, the city replaced it with the Industrial and Commercial Abatement Program, which is more discerning in handing out property tax breaks — just over $5 million this year.
But Parrott said that lawmakers should be watching the new program closely, given the lingering cost of ICIP — which he noted was more than enough to cover the city Parks Department’s annual budget.

The East River Plaza announcement

A 7/26/2010 Forest City Ratner press release headlined East River Plaza grand opening:

New York City Mayor Michael Bloomberg and Bruce C. Ratner, chairman and CEO, Forest City Ratner Companies, were joined by public officials and business partners on Tuesday, July 20, for the official grand opening of East River Plaza.
Bringing Manhattan its first Costco and Target, East River Plaza represents a groundbreaking investment in the East Harlem Community and will contribute to the neighborhood’s continued revitalization. To date, the project has created over 1,100 construction jobs and over 1,000 permanent retail jobs. The development team and retailers have worked closely with New York City Council member Melissa Mark-Viverito, Manhattan Borough President Scott Stringer, the Upper Manhattan Empowerment Zone, the New York City Department of Small Business Services/Workforce 1 and the STRIVE non-profit organization to implement a local hiring program to maximize employment opportunities for local residents. Approximately 70 percent of the new jobs created have gone to residents of Upper Manhattan.
“The opening of East River Plaza culminates the historic transformation of a long vacant and polluted site into a vibrant retail center that is bringing a thousand permanent jobs, tens of millions of dollars in private investment and new shopping opportunities to East Harlem,” said Mayor Bloomberg. “With East River Plaza complete and construction of the nearby East Harlem Media, Entertainment and Cultural Center underway, East Harlem is undergoing a renaissance that will provide new housing, office and retail space and job opportunities for the local community.”
Bruce C. Ratner, chairman and CEO of Forest City Ratner Companies said, “East River Plaza represents the best of public-private partnerships in action. Given the tough economic times we are facing, East River Plaza offers a much needed boost to the economy of New York City, bringing new jobs and generating tax revenues for the City and State. The center also provides new shopping opportunities for East Harlem residents.”
East River Plaza, developed through a joint venture between subsidiaries of Blumenfeld Development Group and Forest City Ratner Companies, is a five-level, 527,000-square-foot retail center in East Harlem. Located on the FDR Drive between 116th Street and 119th Street with direct access to the 1,248-car attached parking facility. In addition to Costco and Target, East River Plaza tenants include national retailers Best Buy, Marshalls, Bob’s Discount Furniture, PetSmart, Kidstown, Old Navy, Verizon and GameStop.
Blumenfeld Development Group and Forest City Ratner Companies, working closely with the leadership of public agencies including the Upper Manhattan Empowerment Zone, Empire State Development Corporation and the New York City Economic Development Corporation, were able to turn this former Brownfield site, once occupied by the Washburn Wire Factory, into a great new shopping destination for all New Yorkers. East River Plaza again shows what is possible when all parties are committed to a successful outcome.

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Uncounted savings on the Barclays Center: perhaps $124 million in free land for developer Forest City Ratner

Today, Mayor Mike Bloomberg delivers his final State of the City address at the new Barclays Center arena, chosen because it has generated “unprecedented economic activity in the area.”

He may even salute some well-publicized elements: an award to the 1 millionth visitor, a new gallery honoring black basketball in Brooklyn, a mural at the Dean Street entrance.

Surely he won't specify how much the arena has cost city taxpayers, and whether that money might have been directed at real public goods, things like open libraries and Head Start.

The city acknowledges $179 million in direct subsidies for land and infrastructure. But the city contribution is far greater than previously analyzed.

As I detail below, free land for the project has been vastly undervalued or not even counted, adding up to nearly $80 million, at least, and likely more than $124 million. The beneficiary: developer Forest City Ratner.

The first two lines in the graphic above regard property the city had long planned to give away. The third line--the streetbed of Pacific Street between Carlton and Vanderbilt avenue--was supposed to be paid for, at least initially. Now, neither the city nor Forest City Ratner will say whether anything was paid.

Beyond that, of course, there are numerous other public subsidies and tax breaks, including $100 million from the state, tax-free bonds, and the rights to develop the MTA's Vanderbilt Yard well below the appraised value, with the cash component of the bid well below that of the one rival bidder.

What we know: from IBO

Yes, people have a vague idea that something's wrong. Just yesterday, New York Times columnist Jim Dwyer made light of the fact that the Barclays Center, which is tax-exempt, was incorrectly listed on city tax rolls. (The New York City Independent Budget Office, or IBO, first pointed that out.)

From IBO 2009 report

How much might the arena cost the city? The best effort--though somewhat dated--to reckon with the arena's fiscal impact came from the IBO in September 2009.

It concluded that the arena would be a net loss to the city over 30 years, as the costs to the current budget--including direct subsidies used for land and infrastructure--would exceed expected tax revenues by $39.5 million.

Beyond that, the city would lose $180.5 million in opportunity costs--mainly from unpaid property taxes on the arena.

That $180.5 million total includes $9.7 million in city property and streets transferred to Forest City. I estimate that number instead at $124.1 million, which would make the opportunity cost total $294.9 million.

Update needed

That report surely could use an update. For one thing, the IBO overestimated the savings--mainly on federal taxes, not city ones--to Forest City Ratner on tax-exempt bonds, because only $511 million in bonds were issued, as opposed to a projected $678 million.

From IBO 2009 report

Also, given the number of expected arena events should increase significantly with the move of the New York Islanders in 2015, local revenues should rise.

Costs missing

Then again, some significant costs were ignored or downplayed.

As the graphic at right indicates, the IBO valued the transfer of city property to Forest City Ratner at $6 million and city streets at $3.7 million.

Those numbers, as I explain below, significantly undervalue the properties. Moreover, the IBO made no attempt to assess the value to Forest City of other city streets transferred to the developer, because the IBO assumed that Forest City would pay fair market value for the land.

There's no evidence Forest City did so.

(Forest City's partnership with Russian billionaire Mikhail Prokhorov, who owns 45% of the arena operating company, means that the Russian oligarch now shares some of the costs and benefits.)

Valuable land, big savings

New York City Economic Development Corporation President Seth Pinsky, in testimony at a May 2009 state Senate oversight hearing, claimed, “Finally, the city has committed to contribute to the project at agreed-upon discounts certain real estate assets for which there are unlikely to be other opportunities for monetization."

Forest City paid dearly for property on the site, and the city just gives it away? Land on the arena block was very valuable--as detailed below--and land nearby is also valuable. Retail rents are skyrocketing. Consider that, as the Wall Street Journal reported 9/16/12:

RedSky Capital LLC paid $4.1 million, or $900 a square foot, for the building at the intersection of Flatbush and Fifth avenues that's housed Triangle Sports a retailer of shoes and sporting goods.

Divide that sum by $900 and the total is about 4556 square feet over three stories, which suggests the plot itself is 1500 square feet. That suggests $300/sf for land. But you can't build high-rise there.

How much is land worth?

Land on the project site is likely worth well more than $300/sf.

At Floor Area Ratio (FAR) of 10--the same FAR used for the appraisal of the Vanderbilt Yard--and a price of $75 per buildable square foot (the assumption in the Vanderbilt Yard appraisal), the land is worth $750/sf.

Both those numbers need adjustments. The approved FAR of the arena block, according to the Land Use chapter of the Atlantic Yards Final Environmental Impact Statement (FEIS), is 8.6, including the streetbeds.

And land is no longer worth $75 per buildable square foot. In 2008, one developer said, the price per buildable sf (PBSF) sought by the city was $150. In 2008, a real estate professional told me, the PBSF was between $110 and $200.

In 2011, according to an analysis from TerraCRG, the PBSF for residential land in Downtown Brooklyn was $161, with an average of $125 for the overall category of Downtown Brooklyn and Park Slope. In 2012, according to TerraCRG, the numbers were $113 and $147, respectively.

Let's use $125 PBSF, a relatively conservative assumption given that the Atlantic Yards site is likely more valuable given its proximity to transit. That suggests land on the arena block is worth 8.6 times $125, or $1075/sf. For convenience, let's round down to $1000/sf.

The MOU's promise

From MOU

According to the 2/18/05 Memorandum of Understanding (MOU) between the city, state, and Forest City, the developer was to get the "City Properties and the City Streets underlying the arena for just $1. (The full MOU is at bottom.)

Initially, the city property on the arena block underneath the adjacent "commercial office building sites"--now, mostly, housing sites--was supposed to generate cash.

Maybe. The MOU cited payment "fair market value... based on an independent appraisal," which took into account "any extraordinary cost" to the developer. In other words, a potential wash.

The IBO, in its first report on Atlantic Yards, in September 2005, low-balled the value of the property under the arena, valuing the streets at only $56,400, based on $20/sf Department of Finance values applied to adjacent land, applied to an area--clearly undercounted--of approximately 2,820 square feet.

The other land on the site, including city properties and streetbeds, was supposed to reap fair market value.

That didn't last.

The deal changes

From 2006 GPP

According to the July 2006 Atlantic Yards General Project Plan (GPP, below), as approved by the Empire State Development Corporation (ESDC), the equation changed somewhat. Property under "the Arena" apparently encompassed the entire arena block. There was no mention of the land underlying the adjacent "commercial office building sites" generating revenue to the city.

However, the other city property within the Atlantic Yards site--the bed of Pacific Street between Carlton and Vanderbilt avenue-- would be acquired "at their fair market appraised value," paid by Forest City.

That didn't last, either.

The deal changes, again

In 2009, Forest City Ratner asked the MTA to revise the Vanderbilt Yard deal and asked the ESDC to agree to acquire the Atlantic Yards site via eminent domain in stages, thus saving the developer on land it didn't need.

From 2009 MGPP

Also, a subtle but key change in the June 2009 Modified General Project Plan (GPP, below) likely hid an additional subsidy.

No longer would the other city property--the aforementioned streetbeds outside the arena block--be acquired "at their fair market appraised value." Alternatively, the payment would be for "such other value as shall be agreed to by the City and FCRC."

How much was the saving on arena block streetbeds? 

Forest City wasn't saving just $56,400 on those streetbeds. In September 2009, the IBO updated its analysis:

The city will provide some property for the project at no cost. According to the latest modified project plan, this will include the street bed of Fifth Avenue between Flatbush and Atlantic Avenues and the street bed of Pacific street between Flatbush and Sixth Avenues, as well as a small traffic triangle at the intersection of Fifth Avenue and Pacific street. Based on recent sales prices in the area, IBO estimates that the 2010 sales value of this property is $3.7 million.

How was that calculated? The IBO said:

The property amounts to approximately 61,625 square feet. The value is based on a price of $60 per square foot, which takes into account the citywide drop in property prices.
In IBO’s 2005 fiscal brief a calculation error led to a significant underestimate of the value of street beds to be transferred.

The calculation error related to the square footage. But the valuation surely was a lowball figure, geared to a city assessment rather than any recognition of the market.

As stated above, the value was likely closer to $1000/sf, given the FAR of 8.6 and the $125 PBSF.

With property covering 61,625 sf--a bit more than 1.4 acres--that suggests the savings on streets is $61,625,000.

What about the other properties?

There were other properties on the arena block. The 2005 IBO report described the transfer of an FDNY site at Block 1127, Lot 33, valued at $93,800 by the Department of Finance.

City property records indicate that the plot was 25 feet x 110 feet, or 2750 square feet. Multiple that by $1000/sf, and the value is $2,750,000.

That sum doesn't looks out of line when compared with that another small property on Block 1127, Lot 20, purchased by Forest City Ratner for $3 million in 2006. (The payment was reimbursed via city taxpayers' $100 million subsidy for land.) Lot 20 looks marginally wider but not as deep.

A footnote in that first IBO report stated that  another city-owned parcel at the tip of the site (Block 1118, Lot 6) was part of Phase 1, but appeared to "be outside the arena building footprint" and thus would be sold at fair market value.

Nope.

The 2009 IBO report acknowledged that the latter property would be included in the city's giveaway, and nudged up the value of the first site. It stated:

The city will also transfer two city-owned parcels to the Empire State Development Corporation (ESDC) at no cost, which will then be leased to FCRC, that appear to be included in the arena site. The first (Block 1127, Lot 33) is valued by the Department of Finance at $124,000 on the current tax roll, and the second (Block 1118, Lot 6) has a reported full market value of $5.8 million.
Based on these market values, the value of the subsidy from ignoring the opportunity to sell these properties is $6.0 million.

That deserves an adjustment. Block 1118, Lot 6, according to property records, covers 13,500 sf, or about .31 of an acre. It's the tip of the arena plaza and the future tip of the area in front of the flagship office tower. It's a prime site.

Even the city, when it assessed the property at $5.8 million, valued it at nearly $430/sf. It's likely worth more. At $1000/sf, given the FAR, it's worth $13,500,000.

Adding it up

The savings on these two city properties is estimated at $16,250,000,

The savings on the streets is estimated at $61,625,000.

Estimated Phase 1 total savings: $77,875,000.

What about Pacific Street in Phase 2?

Another key piece of land is Pacific Street between Carlton and Vanderbilt avenues, demapped for construction staging (trucks line up there), access to the adjacent surface parking lot, and, ultimately, open space to serve the towers surrounding it. This is part of the Phase 2 site but integral to arena operations.

The approved FAR for the project site east of 6th Avenue (Phase 2) is 7.4, including the streetbeds, according to the Final Environmental Impact Statement. Multiply that by $125 PBSF, and the value is $925/sf.

How big is that stretch of Pacific Street (outlined in red)?

It seems roughly commensurate to the Phase 1 streetbeds (blue + yellow) that total 61,625 square feet.

However, just to be conservative, let's call Pacific Street 50,000 square feet, or about 1.15 acres. Multiply that by $925, and the estimated value is $46,250,000.

Total estimated savings: $77,875,000 +  $46,250,000 = $124,125,000.

Of course, a different PBSF would adjust the numbers. Consider: a 20% decrease, with a value of $100 PBSF, would mean total savings of $99.3 million. A 20% increase, with a value of $150 PBSF, would mean total savings of $148.95 million. Also, of course, an adjusted total of Pacific Street square footage would tweak the formula.

How much did Forest City pay?

We don't know exactly what happened with this Phase 2 property. (That street was indeed condemned, addressed in a 9/17/09 board memo and a later legal petition.)

According to the 2005 GPP,  other city property within the Atlantic Yards site was to be acquired "at their fair market appraised value." However, the 2009 MGPP offered a loophole, allowing payment for "such other value as shall be agreed to by the City and FCRC."

What was that value?

It's a mystery. My queries to the mayor's press office, the New York City Economic Development Corporation, and Forest City Ratner have been ignored. A Freedom of Information Law (FOIL) request to the Empire State Development Corporation returned no relevant documents. Other FOIL requests remain pending.

Maybe another city agency, or elected officials, can probe further.

For now, however, my working assumption is that Forest City didn't pay and that the developer, with its allies in the Bloomberg administration, has assumed no one would check.

Atlantic Yards General Project Plan, July 2006 by

Atlantic Yards, Modified General Project Plan, June 2009 by

IBO Atlantic Yards 2009 Fiscal Brief by Eliot Brown / New York Observer

Atlantic Yards Memorandum of Understanding, Feb. 18, 2005 by

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Forest City withdraws suit challenging property assessments, claims mistake; but was it an effort to save not on arena but on other Atlantic Yards buildings?

Forest City Ratner has withdrawn its odd challenge to the city's valuations of its Atlantic Yards properties, claiming the whole thing was a mistake. Or, perhaps, it wasn't, as I suggest below.

As reported by DNAinfo.com, which broke the original story:

In a letter sent to the city’s Law Department and Finance Department on Friday, FCR said it goofed on challenging the appraisals of the Barclays Center and other developments on the 22-acre Atlantic Yards property.

“In challenging the assessments on Forest City properties, petitions on its arena and B2 sites were inadvertently included,” the letter said. “Forest City has instructed our attorneys to discontinue these petitions immediately.”

(The New York Post also followed up, not crediting the publication that came first.)

Update: the letter mentions only those sites. So apparently challenges to assessments on other Atlantic Yards sites continue. Also, given that the letter mentions buildings rather than tax lots, it seems aimed mainly to the media.

Bizarre mistake

It's a pretty bizarre mistake, on a couple of levels. First, they're not paying taxes on tax-exempt land for the arena, just PILOTs, payments in lieu of taxes.

Second, these people are professionals--they're supposed to do better than this.

Looking the wrong way, at least for the arena?

Third, and probably most important, the issue for Forest City Ratner has long been whether assessments were high enough to generate sufficient PILOTs ) to pay off tax-exempt bonds, an issue faced by Yankee Stadium, and why assessments were once dramatically increased.

That's likely part of why only $511 million in tax-exempt bonds were issued, rather than $678 million as once contemplated--a figure the Independent Budget Office in September 2009 suggested could not be supported by PILOTs. As the IBO stated:

If a PILOT is to be used for debt service, it cannot exceed the regular property tax that would apply if the property were not tax-exempt. Concern that a PILOT be high enough to cover the debt service can result in the unusual situation of a property owner hoping for a higher assessment.

Financing plans for the arena

From the Atlantic Yards 2009 Modified General Project Plan, regarding the arena:

ESDC will retain ownership of the land upon which the Arena will be built through the initial term of its lease to the LDC, and, under the financing arrangements described above, ESDC or the LDC will retain ownership of the Arena during the initial term. As a result, the land and improvements will be exempt from real estate taxes throughout the initial term. ArenaCo would enter into a payment-in-lieu-of-tax ("PILOT") agreement with ESDC and the LDC under which it would agree to make payments not to exceed the amount that full real estate taxes would be if the land and improvements were not exempt from such taxes as a result of ESDC's ownership thereof.

Financing plans for the housing

The same document states:

ESDC will retain title to the land underlying other Project developments through their initial construction periods and will lease development parcels to the individual entities created for each of these developments for $1.00. FCRC shall be required to remit payments in lieu of sales taxes to ESDC under the lease or access agreement for each portion of the Project Site equal to all sales and compensating use taxes, if any, which FCRC would have been required to pay in connection with the development of such portion of the Project Site absent ESDC's ownership thereof, other than the Arena Sales Tax Exemption. After completion of construction, the fee interest to each development parcel will be conveyed for $1.00 to the development entity established for that parcel. Following such conveyance, the conveyed parcel will be returned to the tax rolls and will be eligible for any as-of-right tax benefits for which it qualifies, and the fee owner thereof will be liable for real estate taxes due thereon. 

(Emphasis added)

So, could this whole effort have been a ham-handed way to ensure that taxes imposed on the residential buildings would be reduced?

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In lawsuit, Forest City claims arena, land around it worth far less than city assessments; can site for 32-story tower be worth just $6,000?

Could the lot for Forest City Ratner's planned 32-story, 363-unit first tower on the Atlantic Yards site be worth just $6,000?

That's what the developer is claiming, according to legal papers filed recently in state Supreme Court in Brooklyn. The city values the site at more than $400,000, calculating back from an ssessment, set at 45% of gross sales price, of $184,050.

(Documents filed with the Department of Buildings confirm that the site for the tower is Block 1127, Lot 56, or461 Dean Street.)

Could the Barclays Center and its land be worth just $111 million, while the city Department of Finance valued it at about $741 million, with an assessment (45% of value) at about $334 million, as reported by DNAinfo.com?

Remember, the Barclays Center is commonly called a $1 billion building but has been described by the developer as a $934 million project, involving "the cost of this building, the transit connection, the site work, etc."

In the 2009 Modified General Project Plan, Empire State Development, the state agency overseeing the project, said the arena would cost $772 million.

[Update] The New York Post reported:

A Forest City spokesman last night claimed the driving force behind the suit is that the city mistakenly included various properties near the arena on regular tax rolls when they should have been part of the arena’s tax-friendly PILOT program.

Lawsuit raises questions

In a scoop headlined Barclays Center Owners Say City Grossly Overvalued Arena, James Fanelli of DNAInfo reported yesterday on a series of suits (excerpts below) filed in state Supreme Court in Brooklyn, in which affiliates of Forest City Ratner are trying to get property assessments overturned:

The petition says Brooklyn Events asked the city's Tax Commission in the spring to have the property assessment lowered, but the appeal was denied. The petition calls the city's assessment "illegal" and "erroneous."

The whole enterprise is confounding on several counts, notably because Forest City doesn't pay taxes on the arena, only PILOTs (payments in lieu of taxes) to pay off arena construction via tax-exempt bonds.

And Forest City's justifications require a tax attorney to parse: the developer and its affiliates claim various exemptions and special provisions in the tax code beyond my expertise to assess. Forest City wouldn't offer any explanations for the lawsuit to DNAinfo, but the Observer followed up and got this quote:

“The city is still in the process of determining the assessment and until that is concluded we will not comment,” Forest City spokesman Joe DePlasco told The Observer when asked about the discrepancy.

Assessments out of whack, twice?

It is clear that the Department of Finance has both raised and lowered assessments significantly.

 For example, in the tax year ending this June, that Dean Street lot destined for the first tower was assessed by the city at $21,687 (45% of value), while Forest City claimed it was worth $6,000.

Now the assessment is $184,050, an increase of about 8.5 times.

Then again, as I reported in June 2009, the row house at 461 Dean was purchased by FCR on 6/2/04, along with a neighboring building, for $3.8 million, and demolished in the spring of 2006. In 2006, under classification C0 (three-family house), it had a market value of $1.148 million.

In the next year, the classification changed to V1, with a market value of $95,000; the land was assessed at $42,750. In 2008, those numbers rose to $143,000 and $64,350. In the third year, the numbers rose to $998,200 and $449,190.

Shouldn't the site for a 32-story tower be worth a heck of a lot more?

Ay Tax Petition

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