Bankruptcy Sale Does Not Obviate Chapter 91 Compliance

Law360, New York (August 23, 2017, 11:46 AM EDT) -- In another in a series of defeats for taxpayers under N.J.S.A. 54:4-34 (aka Chapter 91), the Tax Court of New Jersey in 975 Holdings LLC v. City of Egg Harbor recently extended Chapter 91’s dismissal provisions to properties purchased through a bankruptcy asset sale pursuant to 11 U.S.C. § 363(f).

The plaintiff, 975 Holdings, purchased the subject property in a § 363(f) bankruptcy asset sale. Prior to the sale, the bankrupt debtor, acting as a debtor-in-possession, failed to respond to the assessor’s request for income and expense information pursuant to N.J.S.A. 54:4-34, known as a Chapter 91 request.[1]

Chapter 91 requires...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS