New York (five boroughs: Manhattan, Brooklyn, Queens, the Bronx, Staten Island), New York
New York City commercial property tax appeals
Appeals start with the NYC Department of Finance, Property Division and go to the Tax Commission of the City of New York. Here is how commercial evidence is built, filed and heard in New York City.
- Assessor
- NYC Department of Finance, Property Division
- First-level board
- Tax Commission of the City of New York
- Filing deadline
- The Tax Commission must receive the application for correction by 5:00 PM on March 1 for Class 2, 3 and 4 property (March 2, 2026 for the 2026/27 roll because March 1 fell on a Sunday) and March 15 for Class 1. A Finance notice of a new or increased assessment dated after February 1 opens a 20-calendar-day window from the date of that notice
- Commercial assessment level
- 45% of market value for Class 4 commercial and Class 2 residential rental property, with increases and decreases in actual assessed value phased in over five years through the transitional assessed value
- Value standard
- Market value as of January 5, based on the property's condition, ownership and use on that date
- Valuation date
- January 5 (taxable status date) preceding the July 1 start of the tax year
- Assessment cycle
- Annual. The Department of Finance revalues every parcel each year and publishes the tentative assessment roll around January 15 for the tax year that begins the following July 1
- Notices mailed
- Notices of Property Value are mailed in mid-January, when the tentative roll is published; revised notices of new or increased assessments can follow after February 1
How New York City assesses commercial property
New York City is the largest single commercial assessment roll in the country, and it runs on a short annual clock. The Department of Finance revalues every parcel each year as of January 5, publishes the tentative roll around January 15, and mails Notices of Property Value in the same weeks. Class 4 commercial property and Class 2 rental buildings are assessed at 45% of market value, but changes in actual assessed value are phased in over five years, so the transitional assessed value usually sets the tax bill.
The only administrative appeal is an application for correction to the Tax Commission, an agency independent of Finance. For Class 2, 3 and 4 property the application must be received by March 1 (March 2 in 2026), and the deadline is set by the City Charter and cannot be extended. Filing is on paper: a notarized original and a copy, a date-stamped TC10 receipt, and for most income-producing property a TC201 income and expense schedule. A $175 fee applies to assessments of $2 million or more, and an owner who skipped the prior year's RPIE filing with Finance is barred from review.
If the Tax Commission does not make an acceptable offer, the owner's attorney commences an Article 7 proceeding in State Supreme Court before October 25. Most commercial cases resolve through Tax Commission offers or Law Department settlements of open petitions, which is why practitioners file every year and keep multiple years of petitions alive.
Major commercial submarkets
- Midtown and Midtown South Manhattan office
- Lower Manhattan and the Financial District
- Long Island City and Astoria, Queens
- Downtown Brooklyn and the Brooklyn Navy Yard
- Hunts Point and the South Bronx industrial corridor
- Jamaica and the JFK airport logistics belt
Uniformity authority
NYC Charter §163(c) (excessive, unequal, unlawful or misclassified assessment); RPTL Article 18 class-share system for special assessing units; RPTL §720(3) (inequality proven against the class ratio)
Appeal statute
NYC Charter §§163 to 166 (application for correction, procedure for assessments of $750,000 or more under §164-a, judicial review under §166); RPTL Article 7
After the board
Article 7 certiorari proceeding (RPTL Article 7, Title 1) in New York State Supreme Court, commenced before October 25 of the tax year (no later than October 23 for 2026/27) and served on the Tax Commission at 1 Centre Street; a timely, valid Tax Commission application is a prerequisite, but a hearing or determination is not
Official forms ATALI ELECTRIC fills for New York City
| Form | Filed with | Purpose |
|---|---|---|
| Form TC101, Application for Correction of Assessed Value of Tax Class Two or Four Property | Tax Commission of the City of New York | Valuation-only appeal for Class 2 and Class 4 property other than condominiums. Commercial condominium units file on TC109, and classification or exemption claims (with or without a value claim) go on TC106. |
| Form TC201, Income and Expense Schedule for Rent Producing Property | Tax Commission, attached to the application (or to Form TC150 for properties assessed at $750,000 or more when figures were not ready by the deadline) | Reports the prior calendar year's rent and expenses. Hotels use TC208, and department stores, public parking garages and lots, and theaters operated by the applicant use TC214. |
| Form TC309, Accountant's Certification | Tax Commission, with Form TC201 | Required when the actual assessment is $5,400,000 or more and rent exceeds $100,000 (the 2026/27 threshold, raised from $5,000,000), so the income and expense figures are reviewed by a certified public accountant. |
| Form TC244, Agent's Statement of Authority and Knowledge | Tax Commission, with a notarized power of attorney | Required whenever an attorney, property manager or other agent signs the application. The agent must have personal knowledge of the property's description, use, income and expenses, and the form cannot be added after filing. |
Filing system: Paper filing only: the signed, notarized original plus one complete copy, filed in person at 1 Centre Street, Room 2400, or a Finance Business Center, or by mail, with a date-stamped Form TC10 receipt as the only proof of timely filing
Hearings and evidence
Applicants choose one option on the application: review on the papers, a personal hearing at the Tax Commission's Manhattan office, a video conference on Microsoft Teams, or a telephone hearing. A Tax Commission hearing officer conducts the hearing, witnesses with personal knowledge testify under oath, and offers of correction arrive on a Notice of Offer and Acceptance Agreement (Form TC70) with about 45 days to accept. Failure to appear for a requested in-person hearing confirms the assessment.
- 01An income and expense schedule is required for most property that earned rental income in the prior calendar year (residential buildings of six or fewer units with no commercial space are excepted); applications missing a required schedule are denied review.
- 02Properties assessed at $750,000 or more may file the income schedule on supplemental Form TC150 from March 2 to March 24 (2026 dates) when figures were not available by the application deadline.
- 03The RPIE law bars Tax Commission review if the owner did not file the prior year's Real Property Income and Expense statement with Finance (due June 1 each year), and no hearing is scheduled for an unresolved RPIE dispute after July 1.
- 04A $175 fee applies when the assessed value on the Notice of Property Value is $2 million or more. It is billed on the property tax bill, not paid with the application, and an unpaid fee can void an offer.
- 05Additional facts after filing go on Form TC159 at the hearing; post-hearing submissions are generally accepted only for information that could not reasonably have been known before the hearing.
Income evidence
Finance values most Class 4 and large Class 2 property by capitalizing net operating income drawn from the owner's RPIE filing and market rent and expense guidelines, then applies the 45% ratio. At the Tax Commission, the case is an income case: a TC201 that ties to the RPIE, a rent roll that reconciles to it, and a market-supported cap rate. Condominiums in Class 2 and 4 are valued as if the whole building were a rental building, so unit sale prices are not used. Because the Tax Commission cannot change Finance's market value estimate directly, the relief arrives as a reduced assessed value offered on Form TC70.
Practitioner notes
- Transitional assessments drive the tax bill for most Class 4 property: a reduction in actual assessed value only lowers the bill when it pulls the actual value below the phased-in transitional value, so model both before deciding how hard to push.
- File the TC101 every year to keep the Article 7 path open. The Tax Commission can review the current year and the prior year only when the prior year has both a complete application and a timely court proceeding.
- Consolidated lots operated as one economic unit need Form TC166 by March 25, or each lot is reviewed on its own income.
- A sale or contract of sale after January 5 two years back must be disclosed on Form TC230, and a transfer that costs the applicant standing has to be cured on TC155 and TC159 before an offer can be accepted.
New York City appeal questions
Last verified October 2026 against the assessor, board and statute.
What is the commercial assessment ratio in New York City?
45% of market value for Class 4 (and for Class 2 and 3). A Class 4 office building Finance values at $60 million carries a $27 million actual assessed value, although increases are phased in over five years through the transitional assessed value.
Can a property tax consultant sign the Tax Commission application?
Only as an agent with personal knowledge of the property's description, use, income and expenses, and only with Form TC244 and a notarized power of attorney attached. The applicant itself must be the owner or another person with standing, never the representative.
Is there an online filing system for applications for correction?
No. Applications need an original, notarized signature and cannot be filed by fax or email. File in person at 1 Centre Street, Room 2400, or a Finance Business Center, or by mail, and keep the date-stamped TC10 receipt.
What happens if the Tax Commission offers nothing?
A timely, valid application preserves the right to commence an Article 7 proceeding in State Supreme Court before October 25 of the tax year, even if no hearing was held. Only a lawyer may represent a corporate petitioner.
Nearby jurisdictions
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