HomeMy WebLinkAbout09-224JUNE 9, 2009 09 -224 RESOLUTION
(CARRIED 7 -0 LOST LAID OVER WITHDRAWN )
PURPOSE: APPROVAL OF SETTLEMENT AGREEMENT WITH WALGREEN
CO. FOR EXCESSIVE ASSESSMENTS FOR PROPERTY LOCATED
AT 950 SOUTH KOELLER STREET
INITIATED BY: LEGAL DEPARTMENT
BE IT RESOLVED by the Common Council of the City of Oshkosh that the attached
Settlement Agreement between the City of Oshkosh and Walgreen Co. is hereby approved
and the proper City officials are hereby authorized to execute and deliver the agreement in
substantially the same form as attached hereto, any changes in the execution copy being
deemed approved by their respective signatures, and said City officials are authorized and
directed to take those steps necessary to implement the terms and conditions of the
Agreement.
BE IT FURTHER RESOLVED that money for this purpose is hereby appropriated
from:
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SETTLEMENT AGREEMENT
Agreement between Walgreen Co. ( "Walgreens "), a corporation organized
and existing under the laws of the State of Illinois and registered and authorized to
conduct business in the State of Wisconsin, and the City of Oshkosh, Wisconsin
(the "City "), a municipal corporation organized and existing under the laws of the
State of Wisconsin.
1. Definitions In this Agreement:
(a) The "Property" means the land and improvement on parcel
number 1308480200 located at 950 South Koeller Street in the City of Oshkosh,
Wisconsin.
(b) "Case" means the action pending in the circuit court for
Winnebago County, Wisconsin titled Walgreen Co. v. City of Oshkosh; Case
No. 08 CV 1192.
(c) "Court" means the Circuit Court for Winnebago County.
(d) A "tax year" means a year in which an assessment is made as
of January 1, with taxes based on the assessment payable in the year following the
tax year.
2. Refund of Taxes for 2007 The City shall issue a refund payable to
Walgreen Co., c/o Robert Hill & Associates IOLTA Trust Account, or to another
account designated by Walgreens in writing, pursuant to Wis. Stat. § 74.37, in the
amount of $8,344.03 as a refund of property taxes previously paid by Walgreens
based on the property tax assessment of the Property for tax year 2007.
3. Reduction of Taxes for 2008 Based on the initial assessment of the
Property for tax year 2008 of $4,093,600, the total property tax liability for the
2008 tax year was $91,577.77 (net of the First Dollar Credit of $28.81). As of the
date of this Settlement Agreement, Walgreens has remitted a total of $68,683.33
against its liability for property taxes based upon the property tax assessment of
the Property for tax year 2008. The City previously granted a partial refund in the
amount of $14,359.96 and, with this Settlement Agreement, supplements this
partial refund with an additional refund amount of $8,456.65, for a total refund of
$22,816.61 for tax year 2008. The refund of $22,816.61 shall be applied to the
payment due on July 31, 2009, leaving a balance due of $77.83.
4. Waiver of Costs and Interest Each party waives all claims for costs.
Except as provided in section 5, Walgreens waives any claim to interest on the
refund amount.
5. Time of Payment The City shall pay the refund of taxes provided in
section 2 of this Agreement in full, no later June 30, 2009. The City shall pay
Walgreens interest on the unpaid principal amount of the refund at the rate of
0.8% per month from June 30, 2009 to the date payment is made.
6. Removal of Case from Trial Calendar Within 5 days of receiving
an executed copy of this Agreement, the parties shall immediately inform the
Court that the parties have entered into a settlement agreement and shall jointly
request the Court to remove the Case from the trial calendar and set aside any
scheduling orders then in effect.
7. Stipulation for Dismissal Within ten days after Walgreens receives
payment in full of the refund of taxes provided in section 2 of this Agreement, the
parties shall:
(a) Enter into a stipulation, in the form attached as Exhibit 1 to
this Agreement and signed by their respective attorneys, for the dismissal of the
Case (including, but not limited to, all claims asserted in the Complaint in the
Case) on the merits, with prejudice, and without costs to either party; and
(b) File the stipulation with the Court.
8. No Admissions of Liability or Concerning Assessments or Fair
Market Value This Agreement is the settlement of disputed claims. Neither party
makes any admission about the assessments or the fair market value of the
Property.
9. Responsibility for Fees and Expenses of Attorneys and Experts
Each party shall be solely responsible for the fees of its attorneys and experts.
10. No Representations Each party acknowledges and agrees that no
representation or promise not expressly contained in this Agreement has been
made by the opposing party or any of its employees, attorneys, agents, or
representatives. Each party acknowledges that it is not entering into this
Agreement on the basis of any such representation or promise, express or implied.
11. Binding on Successors This Agreement shall be binding upon and
inure to the benefit of each of the parties and their respective heirs, successors, and
assigns.
12. Governing Law This Agreement shall be governed and interpreted
by the laws of the State of Wisconsin.
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13. Interpretation of Agreement The parties acknowledge that this
Agreement is the product of joint negotiations. If any dispute arises concerning
the interpretation of this Agreement:
(a) Neither party shall be deemed the drafter of this Agreement
for purposes of its interpretation.
(b) The parties shall attempt in good faith to resolve the dispute.
(c) If the parties cannot resolve the dispute after reasonable
efforts, the dispute shall be submitted to mediation, at the request of either party.
The mediator shall be jointly agreed on by the parties or, if they are unable to
agree, shall be appointed by the Court at the request of either party.
14. Representation By Counsel, Reliance Each party acknowledges that
it has been represented throughout all negotiations leading up to this Agreement
by attorneys of its choice and that its attorneys have approved this Agreement.
Each party represents that in entering into this Agreement, the party has relied on
its own judgment and on the advice of its attorneys, and that no statements or
representations made by the other party or any of its agents, except statements or
representations expressly made in this Agreement, have influenced or induced the
party to sign this Agreement.
15. No Assignment or Transfer Walgreens represents and warrants that
it has not assigned or transferred to anyone and will not assign or transfer to
anyone any of the claims in the Case.
16. Entire Agreement This Agreement states and constitutes the entire
agreement of the parties concerning its subject matter and supersedes all prior or
contemporaneous agreements (written or oral), representations, negotiations, and
discussions concerning its subject matter, including but not limited to, all
agreements (written or oral), representations, negotiations, and discussions made
in the course of mediation of the Case.
17. Use of this Agreement This Agreement shall not be filed with the
Court in this Case or in any other case or proceeding, except for the purpose of
enforcing this Agreement. This Agreement and any part of this Agreement shall
not be admissible in the lawsuit or in any future judicial or administrative
proceeding and shall not be offered as evidence or presented by any Party in the
Lawsuit or any future judicial or administrative proceeding, except for the purpose
of enforcing this Agreement.
18. No Admissions of Liability or Concerning Assessments or Fair
Market Value This Agreement is the settlement of disputed claims. By entering
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into this Agreement, the City does not admit any liability to Walgreens for any of
the claims asserted in the Case or Walgreens' objections to the assessments, and
the payments made under this Agreement shall not be construed as an admission
of any such liability. Neither Party makes an admission about the assessments or
the fair market value of the Property for the tax years 2007 and 2008 or any other
date nor any other admission concerning the assessments of Walgreens' property.
19. Waiver. No waiver of any breach of this Agreement shall be
deemed a continuing waiver of that breach or a waiver of any other breach of this
Agreement.
20. Amendments or Modifications This Agreement may not be
amended, modified or altered in any manner whatsoever, except by a further
written agreement duly authorized and signed by the parties.
21. Authorization to Sign Agreement Each person signing this
Agreement on behalf of either party represents and warrants that the person holds
the position indicated beneath the person's signature and that the person has the
requisite corporate or other authority to sign this Agreement on behalf of the party.
Each party represents that entry into this Agreement is not in contravention of any
agreement or undertaking to which the party is bound.
22. Reading of Agreement Each person signing this Agreement on
behalf of either party acknowledges that the person has read this Agreement, that
the person understands the terms and conditions of this Agreement, that the person
(if other than an attorney for the party) has been advised by legal counsel
concerning this Agreement, and that the person freely and voluntarily signs this
Agreement.
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WALGREEN CO.
By: Reinhart Boerner Van Deuren s.c.
22 East Mifflin Street, Suite 600
Madison, WI 53703
Don M. Millis
State Bar ID No. 1015755
Jessica Hutson Polakowski
State Bar ID No. 1061368
Attorneys for Walgreen Co.
CITY OF OSHKOSH
By: City of Oshkosh Attorney's Office
215 Church Street
Oshkosh, WI 54903
Lynn A. Lorenson
State Bar ID No. 1000821
Date: 5 2009 Date:
REINHART\2759308DMM:DMM 05/23/09
5
2009
CITY HALL
215 Church Avenue
P.O. Box 1130
Oshkosh, 54903-1130 City of Oshkosh
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TO: Honorable Mayor and Members of the Common Council
FROM: Lynn A. Lorenson, City Attorney
DATE: June 3, 2009
RE: Approval of Settlement Agreement with Walgreen Co. for Excessive
Assessments for property located at 950 South Koeller Street
BACKGROUND
Walgreen Co. filed a lawsuit claiming excessive assessments had been levied against
their property located at 950 South Koeller Street and seeking a refund of taxes paid in
relation to that property for the years 2007 and 2008. The City was represented by
Attorney Richard Carlson through the City's insurance carrier. The parties to the lawsuit
participated in mediation with Judge Gordon Myse on May 21, 2009. After the mediation
session, there was additional discussion between the parties and a proposed settlement
was reached. This item is before the Council for approval of the proposed Settlement
Agreement.
ANALYSIS
Assessment of property must be made on the basis of its market value or the full value
that would ordinarily be obtained for the property at a private sale between willing
buyers and sellers. In general, the best indicator of the market value of a property is the
recent sale of that same property. The assessor must carefully examine the
circumstances surrounding each sale to determine whether the sale price may not be
the best indicator of value or whether that sale price may require adjustment to account
for other factors such as favorable financing terms, the inclusion of other items in the
sale price (such as development costs) or other factors.
Q-16
Memo: Walgreen Co.: 6/8/09: Page 2
In 2006 the property located at 950 South Koeller Street was purchased by Inland
Southeast Oshkosh Koeller Street ( "Inland ") for $4,325,000. Inland leases the property
to Walgreen Co. and Walgreen operates under a recognized business model that may
result in Walgreen paying higher- than - market -rate rental payments. This business
model was the subject of litigation with the City of Madison for property tax years 2003
and 2004, resulting in a Supreme Court decision issued July 2008. As the Court
described it, "(u)nder this model, Walgreen rents property rather than purchasing it,
working with developers who find sites for Walgreens' stores at prime locations in
heavily trafficked areas, buy out existing businesses located at the desired sites,
purchase the property, and build and /or develop it with 'super adequacies' to suit
Walgreens needs. Walgreens' lease payments under this business model include
compensation to the developer for all such financing, land acquisition, construction,
development and financing costs, together with a profit margin." Incorporating costs
related to development of the property into the lease may result in lease payments
which are higher than the market rent for comparable properties.
The City Assessor reviewed the sale of the property located at 950 Koeller and adjusted
the sale price down to $3,598,100 to reflect market value of the property based upon
market rents of similar prime commercial properties along the Highway 41 corridor.
Walgreens appeared at the Board of Review to contest the assessment of the property
and thereafter filed a lawsuit claiming that the tax assessed against the property was
excessive. Walgreens claimed that the fair market value of the property was no higher
than $2,200,000. As indicated above, the City and Walgreens participated in a
mediation session with Judge Gordon Myse on May 21, 2009, and thereafter were able
to reach a proposed settlement in this matter. Staff is recommending that the Council
approve the settlement agreement. The proposed settlement establishes the assessed
value of the property at $3,074,000.00. This amount was estimated based upon a fair
market rent within the range of current market rents along the Highway 41 corridor. The
reduction in the assessed value results in a refund of $8344.03 for 2007 and $8456.65
for 2008. In the settlement agreement, Walgreens is agreeing to waive any interest on
the refunded amounts.
With regard to the risks of not approving the proposed settlement, if the City would
proceed to litigation and should not prevail in that litigation, the City would be obligated
to refund any amounts that the court determined were excessive, together with statutory
interest on those amounts. In addition, a prevailing party in litigation may be entitled to
costs which could include the costs of experts retained as well as other costs of
litigation. Should the City not prevail, the City could be assessed additional costs.
Memo: Walgreen Co.: 6/8/09: Page 3
FISCAL IMPACT
The proposed settlement would result in a refund of the assessments issued for 2007
and 2008 for the Walgreens property located at 950 Koeller in the amounts of $8344.03
and $8456.65 respectively for a total refund amount of 16,800.68. There will be no
interest on the refunded amounts. The amount refunded for taxes would include taxes
paid to other taxing entities and the City would be allowed to chargeback the portion of
those taxes attributable to those entities.
RECOMMENDATION
Based upon all of the facts of this case and consideration of the law governing the
assessment process, the Staff recommends that the Council approve the settlement
agreement.
Respectfully Submitted,
Lynn A. Lorenson
City Attorney
Approved:
Mark A. Rohloff
City Manager