Preview
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
Other: Tax
ACKNOWLEDGMENT AND WAIVER OF SERVICE OF TAX PETITION
This Notice shall serve as Acknowledgment of Receipt of the Property Tax Petition identified
below by the Ramsey County Assessor on behalf of itself, the Ramsey County Auditor/Treasurer
and the Ramsey County Attorney.
Petitioner: Brock St Paul Opportunity Business I LLC
Parcel Identification Number: 192922410060,
Date Received: 1/11/2024 Tax Payable Year: 2024
In addition, this Notice shall serve as waiver of personal service of the identified tax petition on
Ramsey County, as required by Minn. Stat. § 278.01, subd. 1(a). This waiver shall not be
interpreted to waive any other statutory or procedural obligation. It is the intention of Ramsey
County that this Notice shall constitute proof of service for purposes of Minn. Stat. § 278.01, subd.
1(c).
Dated: 1/11/2024 On behalf of
PATRICK CHAPMAN
RAMSEY COUNTY ASSESSOR
By:
Staff
Department of the Assessor
Ramsey County
90 West Plato Blvd.
Saint Paul, MN 55107
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT
CASE TYPE 14: OTHER CIVIL
(REAL ESTATE TAX PETITION)
Brock St Paul Opportunity Business I LLC,
Petitioner, PETITION FOR REVIEW OF
REAL PROPERTY TAX
v. ASSESSMENT
County of Ramsey
Court File No. _______________
Respondent.
Petitioner above-named petitions the Court pursuant to the provisions of Minnesota
Statutes Chapter 278 and respectfully pleads certain claims, defenses and objections together with
allegations in support thereof, as follows:
I.
That at all times material Petitioner has had an estate, right, title or interest in the parcel(s)
of real property located in the City of St. Paul, County of Ramsey, and State of Minnesota (the
“property”), described on the attached Exhibit A parcel listing and County property record
information.
II.
That said property, including the land and the improvements located thereon, was valued
and assessed for general real property taxes payable in the year 2024 at an estimated market value
indicated on the assessor’s records by a method of valuation employed by the assessor responsible
for making such valuations.
-1-
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
III.
That said valuation and assessment were and are in excess of the real and actual market
value of said property, and said property is therefore not being taxed equally or fairly with real
property of the same class in the same locality and comparable localities in said City, County and
in the State of Minnesota.
IV.
That the actual market value of property as of the assessment date pertinent herein based
upon comparison with property of the same class and in comparable localities, was substantially
less than the estimated market value placed upon the property by the assessor.
V.
That the aforesaid market value and resultant assessed value as determined by the assessor
for the said property are greater in amount than can lawfully or constitutionally be established or
imposed upon said property; that said values were determined and imposed in an arbitrary and
unreasonable manner and are excessive, non-uniform, unfair, discriminatory, illegal and invalid;
and that the aforesaid tax imposed on the said property by reference to the aforesaid values is
illegal and invalid, being contrary to and in violation of Chapters 272-276 and 278 of Minnesota
Statutes, Article I, Section 7 and Article X, Section 1 of the Constitution of Minnesota, and the
Fourteenth Amendment of the Constitution of the United States.
VI.
That no proceeding of any kind for the correction of the assessment against the aforesaid
real property for the years in question is pending in any court.
-2-
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
WHEREFORE, petitioner, Brock St Paul Opportunity Business I LLC, prays that the Court
determine the validity of petitioner’s claims, defenses and objections and make its Order as
follows:
1. Determining that the estimated market value, resulting assessed value and general
taxes on said real property should be reduced in accordance with the evidence, and
the laws of the State of Minnesota and the United States;
2. Determining the proper classification for said property;
3. Determining that petitioner recover interest at the legal rate on that amount of the
general real estate taxes paid in excess of the Court determination herein;
4. Determining that petitioner recover its legal fees, costs and disbursements; and
5. Granting such other and further relief as the Court may determine just and
equitable.
The undersigned party by its attorney hereby acknowledges that costs, disbursements and
reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. § 549.211, to the
party against whom the allegations in this pleading are asserted.
Dated: January 4, 2024 THE LAW OFFICES OF
JEFFERY J. MCNAUGHT
/s/ Jeffery J. McNaught
Jeffery J. McNaught
Attorney Registration No. 164665
201 Ridgewood Avenue
Minneapolis MN 55403
Phone: 612-578-8455
jeff@jmcnaughtlaw.com
ATTORNEY FOR PETITIONER
-3-
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
EXHIBIT A
PROPERTY IDENTIFICATION ESTIMATED MARKET VALUE
19-29-22-41-0060 8,455,200
-4-
_D _ X|192922410060|1|0
192922410060_2024_PROPOSED
62-CV-24-426 Proposed 2024 192922410060 Filed in District Court
State of Minnesota
2024 Proposed Property Tax 1/23/2024 2:37 PM
This is NOT a bill. DO NOT PAY!
90 Plato Blvd. West • Saint Paul, MN
651-266-2000 • AskPropertyTaxandRecords@ramseycounty.us Taxes Payable Year 2023 2024
ramseycounty.us/Property Estimated Market Value 8,041,500 8,455,200
Green Acres Value 0 0
Plat Deferment 0 0
Disabled Vets Exclusion 0 0
Step Homestead Market Exclusion 0 0
BROCK ST PAUL OPPORTUNITY BUSINESS I LLC
488*2**G48**0.697**1/2*********SNGLP
C/O TIG CENTRAL TEXAS
1 Taxable Market Value
Property Classification
8,041,500
INDUSTRIAL
8,455,200
INDUSTRIAL
BROCK ST PAUL
901 S MOPAC OPPORTUNITY
EXPY BUSINESS
BLDG IV # STE 285 I LLC
C/O TIG CENTRAL TEXAS
AUSTIN
901 TX 78746-5776
S MOPAC EXPY BLDG IV # STE 285
AUSTIN TX 78746-5776
Proposed Tax Notice
CURRENT
Step
STEP
2
PIN/Property Address/Abbreviated Tax Description
192922410060 0151 Property Taxes After Credits 284,104.00
240 ARLINGTON AVE E
ARLINGTON BUSINESS PARK VAC ST The time to provide feedback on proposed levies is now.
ACCRUING & FOL; PART LYING WLY OF The only way to appeal your value at this time is by going
...G AND LOTS 1 & LOT 2 BLK 3 to tax court. For more information call: 651-539-3260
Step Property Tax Statement
3 Coming March 2024
PROPOSED PROPERTY TAXES AND MEETINGS BY JURISDICTION FOR YOUR PROPERTY
Column 1 Column 2 Tax and Budget
Contact Information 2023 Tax – Actual 2024 Tax – Proposed Meetings and Locations
Ramsey County 43,414.50 49,079.50 December 6 at 6 p.m.
Regional Railroad Authority 3,885.14 4,687.20 Virtual and in-person options are available.
Visit ramseycounty.us/PublicHearings
Ramsey County for details.
15 W. Kellogg Blvd., Suite 250
In-person location:
Saint Paul, MN 55102
Maplewood YMCA Community Center
651-266-2222 2100 White Bear Ave.
ramseycounty.us
Maplewood, MN 55109
ST PAUL 47,804.96 51,030.18 DECEMBER 5, 2023 AT 6:00 PM
City Library 5,580.66 6,161.52
CITY OF SAINT PAUL CITY HALL COUNCIL CHAMBERS
15 W KELLOGG BLVD 15 W KELLOGG BLVD
ST PAUL, MN 55102 ST PAUL, MN 55102
(651) 266-6805
STPAUL.GOV
State General Tax 52,088.64 49,831.20 No Meeting Required
ISD #625 DECEMBER 5, 2023 AT 6:00 PM
ISD 625 SAINT PAUL PUBLIC SCHOOLS
360 COLBORNE STREET ADMINISTRATIVE BUILDING
ST. PAUL, MN 55102 360 COLBORNE STREET
(651) 767-8100 ST. PAUL, MN 55102
SPPS.ORG
a. Voter approved levies 7,310.04 7,689.24
b. Other local levies 40,216.48 43,227.56
Metropolitan Special Taxing Districts 2,131.72 2,191.28
Metropolitan Council December 13 at 6 p.m.
390 Robert St. N. Council Chambers
Saint Paul, MN 55101 390 Robert St. N.
651-602-1738 Saint Paul, MN 55101
metrocouncil.org/budget
Other special taxing districts 7,298.38 8,218.44 No Meeting Required
Tax increment 0.00 0.00 No Meeting Required
Fiscal disparity 72,963.48 61,987.88 No Meeting Required
Total Tax excluding special assessments 282,694.00 284,104.00
Percent of Tax Change 0.50%
Your local units of government have proposed the amount of property taxes Column 1 above shows your actual 2023 property taxes.
that they will need for 2024. Any upcoming referendums, legal judgments, Column 2 above shows what your 2024 property taxes will be if
natural disasters, voter approved levy limit increases, or special assessments your local jurisdictions approve the property tax amounts they
could change these amounts. are now considering.
Your county commissioners, school board, city council and metropolitan special taxing districts will soon be holding public meetings to
discuss their proposed 2024 budgets and proposed 2024 property taxes. The school board will discuss the 2023 budget. You are invited to
attend these meetings to share your feedback. The meeting places and times are listed above. Also shown are the addresses and telephone numbers
for these local units of government if you have comments or questions concerning the proposed property tax amounts shown on this notice.
No meeting is required if your city has a population of less than 500 people. There is also no public hearing on the state general tax.
This is NOT a bill. Do not pay! Request translation services: 651-266-8500
For additional information about this notice, Español | Hmoob | Soomaali | Afaan Oromoo |
visit: ramseycounty.us/Property
11-3-23_V2
488 1/1
62-CV-24-426
Filed in District Court
State of Minnesota
1/23/2024 2:37 PM
ADMISSION OF SERVICE
Due and personal service of the within Petition is admitted at ______________, Minnesota,
on ______________________, 2024.
Date: ____________________, 2024 _________________________________
County Auditor
Due and personal service of the within Petition is admitted at ______________, Minnesota,
on ______________________, 2024.
Date: ____________________, 2024 _________________________________
County Treasurer
Due and personal service of the within Petition is admitted at ______________, Minnesota,
on ______________________, 2024.
Date: ____________________, 2024 _________________________________
County Assessor
Due and personal service of the within Petition is admitted at ______________, Minnesota,
on ______________________, 2024.
Date: ____________________, 2024 _________________________________
County Attorney
Preview
62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT Other: Tax ACKNOWLEDGMENT AND WAIVER OF SERVICE OF TAX PETITION This Notice shall serve as Acknowledgment of Receipt of the Property Tax Petition identified below by the Ramsey County Assessor on behalf of itself, the Ramsey County Auditor/Treasurer and the Ramsey County Attorney. Petitioner: Brock St Paul Opportunity Business I LLC Parcel Identification Number: 192922410060, Date Received: 1/11/2024 Tax Payable Year: 2024 In addition, this Notice shall serve as waiver of personal service of the identified tax petition on Ramsey County, as required by Minn. Stat. § 278.01, subd. 1(a). This waiver shall not be interpreted to waive any other statutory or procedural obligation. It is the intention of Ramsey County that this Notice shall constitute proof of service for purposes of Minn. Stat. § 278.01, subd. 1(c). Dated: 1/11/2024 On behalf of PATRICK CHAPMAN RAMSEY COUNTY ASSESSOR By: Staff Department of the Assessor Ramsey County 90 West Plato Blvd. Saint Paul, MN 55107 62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM STATE OF MINNESOTA DISTRICT COURT COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT CASE TYPE 14: OTHER CIVIL (REAL ESTATE TAX PETITION) Brock St Paul Opportunity Business I LLC, Petitioner, PETITION FOR REVIEW OF REAL PROPERTY TAX v. ASSESSMENT County of Ramsey Court File No. _______________ Respondent. Petitioner above-named petitions the Court pursuant to the provisions of Minnesota Statutes Chapter 278 and respectfully pleads certain claims, defenses and objections together with allegations in support thereof, as follows: I. That at all times material Petitioner has had an estate, right, title or interest in the parcel(s) of real property located in the City of St. Paul, County of Ramsey, and State of Minnesota (the “property”), described on the attached Exhibit A parcel listing and County property record information. II. That said property, including the land and the improvements located thereon, was valued and assessed for general real property taxes payable in the year 2024 at an estimated market value indicated on the assessor’s records by a method of valuation employed by the assessor responsible for making such valuations. -1- 62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM III. That said valuation and assessment were and are in excess of the real and actual market value of said property, and said property is therefore not being taxed equally or fairly with real property of the same class in the same locality and comparable localities in said City, County and in the State of Minnesota. IV. That the actual market value of property as of the assessment date pertinent herein based upon comparison with property of the same class and in comparable localities, was substantially less than the estimated market value placed upon the property by the assessor. V. That the aforesaid market value and resultant assessed value as determined by the assessor for the said property are greater in amount than can lawfully or constitutionally be established or imposed upon said property; that said values were determined and imposed in an arbitrary and unreasonable manner and are excessive, non-uniform, unfair, discriminatory, illegal and invalid; and that the aforesaid tax imposed on the said property by reference to the aforesaid values is illegal and invalid, being contrary to and in violation of Chapters 272-276 and 278 of Minnesota Statutes, Article I, Section 7 and Article X, Section 1 of the Constitution of Minnesota, and the Fourteenth Amendment of the Constitution of the United States. VI. That no proceeding of any kind for the correction of the assessment against the aforesaid real property for the years in question is pending in any court. -2- 62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM WHEREFORE, petitioner, Brock St Paul Opportunity Business I LLC, prays that the Court determine the validity of petitioner’s claims, defenses and objections and make its Order as follows: 1. Determining that the estimated market value, resulting assessed value and general taxes on said real property should be reduced in accordance with the evidence, and the laws of the State of Minnesota and the United States; 2. Determining the proper classification for said property; 3. Determining that petitioner recover interest at the legal rate on that amount of the general real estate taxes paid in excess of the Court determination herein; 4. Determining that petitioner recover its legal fees, costs and disbursements; and 5. Granting such other and further relief as the Court may determine just and equitable. The undersigned party by its attorney hereby acknowledges that costs, disbursements and reasonable attorney and witness fees may be awarded pursuant to Minn. Stat. § 549.211, to the party against whom the allegations in this pleading are asserted. Dated: January 4, 2024 THE LAW OFFICES OF JEFFERY J. MCNAUGHT /s/ Jeffery J. McNaught Jeffery J. McNaught Attorney Registration No. 164665 201 Ridgewood Avenue Minneapolis MN 55403 Phone: 612-578-8455 jeff@jmcnaughtlaw.com ATTORNEY FOR PETITIONER -3- 62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM EXHIBIT A PROPERTY IDENTIFICATION ESTIMATED MARKET VALUE 19-29-22-41-0060 8,455,200 -4- _D _ X|192922410060|1|0 192922410060_2024_PROPOSED 62-CV-24-426 Proposed 2024 192922410060 Filed in District Court State of Minnesota 2024 Proposed Property Tax 1/23/2024 2:37 PM This is NOT a bill. DO NOT PAY! 90 Plato Blvd. West • Saint Paul, MN 651-266-2000 • AskPropertyTaxandRecords@ramseycounty.us Taxes Payable Year 2023 2024 ramseycounty.us/Property Estimated Market Value 8,041,500 8,455,200 Green Acres Value 0 0 Plat Deferment 0 0 Disabled Vets Exclusion 0 0 Step Homestead Market Exclusion 0 0 BROCK ST PAUL OPPORTUNITY BUSINESS I LLC 488*2**G48**0.697**1/2*********SNGLP C/O TIG CENTRAL TEXAS 1 Taxable Market Value Property Classification 8,041,500 INDUSTRIAL 8,455,200 INDUSTRIAL BROCK ST PAUL 901 S MOPAC OPPORTUNITY EXPY BUSINESS BLDG IV # STE 285 I LLC C/O TIG CENTRAL TEXAS AUSTIN 901 TX 78746-5776 S MOPAC EXPY BLDG IV # STE 285 AUSTIN TX 78746-5776 Proposed Tax Notice CURRENT Step STEP 2 PIN/Property Address/Abbreviated Tax Description 192922410060 0151 Property Taxes After Credits 284,104.00 240 ARLINGTON AVE E ARLINGTON BUSINESS PARK VAC ST The time to provide feedback on proposed levies is now. ACCRUING & FOL; PART LYING WLY OF The only way to appeal your value at this time is by going ...G AND LOTS 1 & LOT 2 BLK 3 to tax court. For more information call: 651-539-3260 Step Property Tax Statement 3 Coming March 2024 PROPOSED PROPERTY TAXES AND MEETINGS BY JURISDICTION FOR YOUR PROPERTY Column 1 Column 2 Tax and Budget Contact Information 2023 Tax – Actual 2024 Tax – Proposed Meetings and Locations Ramsey County 43,414.50 49,079.50 December 6 at 6 p.m. Regional Railroad Authority 3,885.14 4,687.20 Virtual and in-person options are available. Visit ramseycounty.us/PublicHearings Ramsey County for details. 15 W. Kellogg Blvd., Suite 250 In-person location: Saint Paul, MN 55102 Maplewood YMCA Community Center 651-266-2222 2100 White Bear Ave. ramseycounty.us Maplewood, MN 55109 ST PAUL 47,804.96 51,030.18 DECEMBER 5, 2023 AT 6:00 PM City Library 5,580.66 6,161.52 CITY OF SAINT PAUL CITY HALL COUNCIL CHAMBERS 15 W KELLOGG BLVD 15 W KELLOGG BLVD ST PAUL, MN 55102 ST PAUL, MN 55102 (651) 266-6805 STPAUL.GOV State General Tax 52,088.64 49,831.20 No Meeting Required ISD #625 DECEMBER 5, 2023 AT 6:00 PM ISD 625 SAINT PAUL PUBLIC SCHOOLS 360 COLBORNE STREET ADMINISTRATIVE BUILDING ST. PAUL, MN 55102 360 COLBORNE STREET (651) 767-8100 ST. PAUL, MN 55102 SPPS.ORG a. Voter approved levies 7,310.04 7,689.24 b. Other local levies 40,216.48 43,227.56 Metropolitan Special Taxing Districts 2,131.72 2,191.28 Metropolitan Council December 13 at 6 p.m. 390 Robert St. N. Council Chambers Saint Paul, MN 55101 390 Robert St. N. 651-602-1738 Saint Paul, MN 55101 metrocouncil.org/budget Other special taxing districts 7,298.38 8,218.44 No Meeting Required Tax increment 0.00 0.00 No Meeting Required Fiscal disparity 72,963.48 61,987.88 No Meeting Required Total Tax excluding special assessments 282,694.00 284,104.00 Percent of Tax Change 0.50% Your local units of government have proposed the amount of property taxes Column 1 above shows your actual 2023 property taxes. that they will need for 2024. Any upcoming referendums, legal judgments, Column 2 above shows what your 2024 property taxes will be if natural disasters, voter approved levy limit increases, or special assessments your local jurisdictions approve the property tax amounts they could change these amounts. are now considering. Your county commissioners, school board, city council and metropolitan special taxing districts will soon be holding public meetings to discuss their proposed 2024 budgets and proposed 2024 property taxes. The school board will discuss the 2023 budget. You are invited to attend these meetings to share your feedback. The meeting places and times are listed above. Also shown are the addresses and telephone numbers for these local units of government if you have comments or questions concerning the proposed property tax amounts shown on this notice. No meeting is required if your city has a population of less than 500 people. There is also no public hearing on the state general tax. This is NOT a bill. Do not pay! Request translation services: 651-266-8500 For additional information about this notice, Español | Hmoob | Soomaali | Afaan Oromoo | visit: ramseycounty.us/Property 11-3-23_V2 488 1/1 62-CV-24-426 Filed in District Court State of Minnesota 1/23/2024 2:37 PM ADMISSION OF SERVICE Due and personal service of the within Petition is admitted at ______________, Minnesota, on ______________________, 2024. Date: ____________________, 2024 _________________________________ County Auditor Due and personal service of the within Petition is admitted at ______________, Minnesota, on ______________________, 2024. Date: ____________________, 2024 _________________________________ County Treasurer Due and personal service of the within Petition is admitted at ______________, Minnesota, on ______________________, 2024. Date: ____________________, 2024 _________________________________ County Assessor Due and personal service of the within Petition is admitted at ______________, Minnesota, on ______________________, 2024. Date: ____________________, 2024 _________________________________ County Attorney