Appeal guide · New York
How to appeal a commercial assessment in New York City
8 steps from the notice to the Tax Commission of the City of New York and beyond, with the forms, exchange deadlines and mistakes that decide commercial cases here.
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
Where to file
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
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
The process, in order
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.
Forms you will need
- +Form TC101, Application for Correction of Assessed Value of Tax Class Two or Four Property
- +Form TC201, Income and Expense Schedule for Rent Producing Property
- +Form TC309, Accountant's Certification
- +Form TC244, Agent's Statement of Authority and Knowledge
- 1
Mid-January, when the tentative roll is published
Read the Notice of Property Value
Confirm the tax class, Finance's market value, the actual and transitional assessed values, and the income figures Finance used. Compare market value times 45% against the actual assessed value on the notice.
- 2
Before filing
Confirm RPIE compliance
Verify the prior year's RPIE statement was filed with Finance by June 1. Non-compliance bars Tax Commission review, and the dispute must be resolved with Finance, not the Tax Commission.
- 3
January to February
Build the TC201 and supporting schedules
Prepare the prior calendar year's income and expense schedule, the TC309 accountant's certification if the assessment is $5,400,000 or more and rent exceeds $100,000, and TC200 or TC230 if a lease, sale or construction must be disclosed.
- 4
Received by 5:00 PM on March 1 (Class 2, 3 and 4)
File the application for correction
File the notarized TC101 (or TC109 for condominium units, TC106 for classification or exemption claims) with one copy and a TC10 receipt. Agents must attach TC244 and a notarized power of attorney.
- 5
TC150 from March 2 to March 24 (2026); TC166 by March 25
Supplement the record
Properties assessed at $750,000 or more can file a late-available income schedule on TC150. Related lots operated as one unit are reported on TC166 for consolidated review.
- 6
Hearings scheduled through the spring and summer
Attend the hearing or rest on the papers
Appear in Manhattan, by Microsoft Teams or by telephone, or let the papers speak. Bring additional facts on Form TC159 and a witness with personal knowledge of the income and expenses.
- 7
Determinations generally by October 1; about 45 days to accept a TC70 offer
Accept or reject the offer
An accepted offer reduces the assessment and requires stipulations of discontinuance for open prior-year petitions. Finance issues the revised assessment and any remission.
- 8
Before October 25 of the tax year
Commence the Article 7 proceeding
Counsel buys an index number, serves the petition on the Tax Commission at 1 Centre Street and files with the County Clerk. The proceeding preserves the year for later settlement with the Law Department or trial.
Mistakes that lose New York City appeals
- Missing the March 1 receipt deadline; mailed applications count only when received, and proof of mailing is not proof of filing.
- Filing without a required TC201, TC309 or TC244, or with an agent signature unsupported by a notarized power of attorney; these defects cannot be cured after filing.
- Skipping the prior year's RPIE filing with Finance, which bars Tax Commission review of the current application.
- Arguing the actual assessed value down without checking the transitional assessed value, so a won reduction produces no tax savings.
- Letting the October 25 Article 7 deadline pass, which ends the year for good and breaks the two-year review the Tax Commission can otherwise offer.
Evidence rules
- 1.An 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.
- 2.Properties 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.
- 3.The 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.
- 4.A $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.
- 5.Additional 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.
Frequently asked
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.
File a stronger New York City appeal this cycle.
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