Chelmsford Wins Victory in Mobile Home Park Appellate Tax Board Case

Assessment cases involving mobile home parks are rare, and there is little precedent for municipal officials to follow. Now, in the case CJD Real Estate Limited Partnership v. Board of Assessors of the Town of Chelmsford, et al., (Appellate Tax Board Nos. F298316 & F304236) the Appellate Tax Board (“ATB”) has rejected a mobile home park’s claim that its property was worth $3,880,500, and valued it at $10,000,000 and $9,938,300 for fiscal years 2008 and 2009 respectively.

The subject property consisted of approximately 37.75 acres, improved with roads, 254 site pads, and other infrastructure necessary for the operation of a manufactured home community. The park owner, CJD, claimed that it was entitled to the benefit of the exemption from taxation enjoyed by the individual mobile home owners. At trial, the Town presented facts and law that clearly demonstrated CJD’s position on its supposed entitlement to an exemption was meritless.

The Town’s case proved the value of the Appellant’s property by using the income approach to valuation. This was consistent with CJD’s witnesses’ testimony that CJD derives income from the rental of site pads on which manufactured homes are parked. The ATB concluded that the use of the income approach to valuation was proper in assessing the park, and consistent with the manner in which mobile home park owners themselves value such properties for investment purposes.