Tribunals Ontario
Tribunaux décisionnels Ontario
Assessment Review Board
Commission de révision de l’évaluation foncière
ISSUE DATE: February 9, 2022
Assessed Persons: Jay Patry Enterprises LLC and Jay Patry Enterprises Inc.
Appellant: Jay Patry Enterprises Inc.
Respondent: Municipal Property Assessment Corporation Region 05
Respondent: City of Kingston
Property Location: 539 Armstrong Road
Municipality: City of Kingston
Roll Number: 1011-080-180-00300-0000
Appeal Numbers: 3244127, 3292469, 3348237, 3457465 and 3457466
Taxation Years: 2017, 2018, 2019, 2020 and 2021
Hearing Event No.: 752067
Legislative Authority: Section 40 of the Assessment Act, R.S.O. 1990, c. A.31
APPEARANCES:
| Parties | Counsel*/Representative |
|---|---|
| Jay Patry Enterprises Inc. | Roberto Aburto*, Michelle J.T. Cicchino* |
| Municipal Property Assessment Corporation | David Cowling*, Simon Sigler* |
| City of Kingston | Jeff Walker |
HEARD: December 8 and 9, 2021 by video conference call
ADJUDICATORS: Christopher Voutsinas, Vice Chair, Jean-Paul Pilon, Member
DECISION
OVERVIEW
1Jay Patry Enterprises Inc. (the “Appellant”) is the owner of 539 Armstrong Road in the City of Kingston (the “Subject Property”). The Appellant appeals the assessment of the Subject Property for the 2017 taxation year, and further appeals were deemed for the 2018 to 2021 taxation years pursuant to section 40(26) of the Assessment Act, R.S.O. 1990, c. A.31 (the “Act”). The Appellant’s ground for appeal is that the current assessed value of the Subject Property for the taxation years in question is incorrect and too high.
2The Municipal Property Assessment Corporation (“MPAC”) took the position that the current assessed value of the Subject Property for the 2017 to 2021 taxation years is too low.
3The City of Kingston, the municipality in which the Subject Property is located, is a statutory party to the appeals. However, its participation in the appeals was limited to having an observer present at the hearing who did not participate in the hearing.
Background
4Section 19(1) of the Act provides that the assessment of land shall be based on its current value. Section 1 of the Act defines current value as “… the amount of money the fee simple, if unencumbered, would realize if sold at arm’s length by a willing seller to a willing buyer.” For the 2017 to 2021 taxation years, the valuation date is January 1, 2016.
5These appeals relate to a multi-family residential property containing 113 units. MPAC, through its mass appraisal process, assessed the property at $20,115,000 and, after further review and analysis in the context of these appeals, considered the current value to be $21,997,000. The Appellant considered the current value to be $16,300,000.
6Both parties agreed that the income approach was the best approach to determine the current value of the Subject Property, although the Appellant also used the direct comparison approach in its analysis as a “check” on its result from the income approach, which MPAC rejected taking the position that there were no properties sufficiently comparable to the Subject Property to be used in such an analysis.
7The key issue in this proceeding was the determination of the current value of the Subject Property and, in particular, the determination of the appropriate capitalization rate (“cap rate”) to be applied to the net operating income (“NOI”) of the Subject Property.
8The Board previously considered the correct current value of the Subject Property in Jay Patry Enterprises Inc. v Municipal Property Assessment Corporation, Region 05, 2018 ON ARB 70338 (“Patry”). The primary question to be determined in that decision was the correct current value of the Subject Property as of January 1, 2012, as was set out in para. 11 of that decision. The primary question to be determined in this decision is materially different and is, instead, the correct current value of the Subject Property as of January 1, 2016, not January 1, 2012. In addition, given that the Board had sufficient and current expert evidence before it at this hearing to arrive at a determination of the correct current value of the Subject Property, reference to the dated evidence in Patry was unnecessary. The Board therefore finds that the previous decision has no bearing on this new question to be determined by the Board in these appeals.
Areas of Agreement
9The parties agreed that the income approach was the best approach for determining the current value of the Subject Property.
10There was no dispute among the parties regarding the classification of the Subject Property.
11The parties agreed that the current use represented the highest and best use of the Subject Property.
Issues for the Hearing
12At issue in this proceeding were the following:
- What was the NOI of the Subject Property to be used for valuation purposes?
- What was the cap rate for the Subject Property to be used in determining value?
- Was the direct comparison approach appropriate, under the circumstances, for valuing the Subject Property?
- What was the current value of the Subject Property?
- Was an equitable reduction of the current value required, and if so, how much?
Result
13The Board finds that the current value of the Subject Property is $20,103,701.
14The Board finds that an equitable adjustment of the correct current value of the Subject Property is warranted, and accordingly reduces that value to $18,495,405 or $18,500,000, rounded.
ANALYSIS
Description of Subject Property
15The Subject Property is a class ‘B’, four-storey multi-residential rental building comprised of 113 self-contained units. Of these, 30 are one-bedroom units, 64 are two-bedroom units, and 19 are three-bedroom units. Built in 2012, the property includes a number of on-site amenities such as a social/party room, a fitness gym, a children’s playground, and a rooftop patio. The building has two 15-person elevators and is fully equipped with sprinklers.
16The Subject Property sits on a land lot of approximately 2.9 acres and is located in the Kingston West area of the City of Kingston. The property benefits from good access to bus service and is in a central location relative to shopping and employment sources.
17The parties relied on expert valuation reports prepared by Emily Corsi for MPAC and Stephen Rayner for the Appellant. MPAC used the income approach to determine the current value of the Subject Property, while the Appellant used both the income and the direct comparison approaches to determine the current value of the Subject Property. The Appellant submitted that the direct comparison approach was a ‘check’ to confirm the accuracy of its analysis using the income approach.
18The income approach involves applying an appropriate cap rate reflecting an investor’s long-term return expectation to the net operating income that a real property generates. Several steps are involved in the determination of value using the income approach.
19The first step of the income approach requires a determination of the potential gross income (“PGI”) that the Subject Property can generate at full occupancy. The second step involves determining an allowance for vacancy loss and collection loss (or bad debt) to derive the property’s effective gross income (“EGI”). The third step involves estimating the total annual operating expenses necessary to operate the property and maintain the income stream. Then, the estimated total annual expenses are deducted from EGI to obtain the property’s NOI. Finally, a market-based cap rate applicable to the property is applied to the NOI to calculate value.
20The parties agreed that the income capitalization calculation may be performed by either including or excluding property taxes from operating expenses, provided that the correct corresponding cap rate is used. Specifically, if property taxes are excluded from operating expenses, the base cap rate (where the NOI has property taxes included in expenses) must be adjusted by adding the appropriate tax rate applicable to the property. In this case, the applicable 2016 tax rate for new multi-residential property in the City of Kingston was 1.27%.
Issue 1 – What was the NOI of the Subject Property?
21MPAC’s expert testified that the PGI for the Subject Property was $1,961,256, while the Appellant’s expert arrived at a PGI of $1,952,078, a difference of only $9,178. After deducting their respective figures for vacancy loss, credit loss and operating expenses, excluding property taxes as expenses, MPAC’s NOI for the Subject Property was $1,489,235 and the Appellant’s was $1,439,426.
22During the hearing, MPAC accepted that the Board could proceed using the Appellant’s expert’s NOI figure as this figure was not significantly different from the NOI arrived at by MPAC’s expert. The Board agreed to accept the Appellant’s NOI figure on the basis of MPAC’s concession.
Finding on Issue 1
23The Board finds that the NOI excluding property taxes from expenses of the Subject Property is $1,439,426 for valuation purposes.
Issue 2 – What is the capitalization rate for the Subject Property?
Determining Capitalization Rate
24The final step in determining value using the income approach involves finding the appropriate cap rate for the property based on actual market activity and the implied return expectation of purchasers/investors. This is accomplished by analyzing the sale prices of comparable properties achieved in the market relative to the NOIs generated by those properties. The determined cap rate is then applied to the NOI of the property to derive the value of the property. Specifically, current value is calculated by dividing NOI by the cap rate.
MPAC’s Position
25MPAC used a base cap rate of 5.5% in its analysis. To that, it added the applicable tax rate of 1.27%. Using the approach of not including property taxes in expenses and adding the tax rate to the base cap rate, an approach that was also used by the Appellant, MPAC arrived at an overall cap rate of 6.77%.
26MPAC’s expert witness testified that she searched MPAC’s corporate database for sales information and identified what she considered were four comparable property sales with base cap rates that ranged from 4.6% to 6.5%. These properties sold between April 2016 and September 2017, with sale prices that ranged from $1.17 million to $49.7 million. MPAC did not provide the number of units in each property for comparison purposes. MPAC also time-adjusted the actual sale prices to simulate what each of these properties would have sold for as of the valuation date of January 1, 2016. MPAC’s expert testified that they calculated the corresponding NOI of each property sale using fair-market rents.
27The resulting median time-adjusted cap rate of the four sales was 5.0% with an average of 5.27%. MPAC concluded that a “fair and appropriate” cap rate for the subject property was 5.5%, reflecting the average of the range shown in a market report prepared by Rogers & Trainor Commercial Realty Inc. submitted into evidence, to which MPAC’s expert witness added a further 1.27% for property taxes.
Appellant’s Position
28The Appellant, on the other hand, used a base cap rate of 7.25% and added the same 1.27% applicable tax rate to arrive at an overall cap rate of 8.52%.
29The Appellant’s 7.25% base cap rate was derived from five property sales using actual sale prices that were not time-adjusted. The total number of units in each property ranged from 10 to 26, when the Subject Property has 113 units, with sale prices that ranged from $783,627 to $2,565,000. The Appellant’s witness testified that the cap rates for these properties ranged from 5.78% to 8.59%.
30The Appellant’s expert witness testified that rents in the Subject Property are “substantially above the norm for the area” and that a potential purchaser would use a “higher than normal capitalization rate given the lack of upside potential on rents and potential for rental reductions.”
31The Appellant’s expert concluded that due to the above market rents at the Subject Property and the use of, to quote from his report, “proper expenses for categories such as Replacement Reserves and Repairs and Maintenance, the condition and location of the building, and factoring in rental rates,” that 7.25% was a reasonable base cap rate for the Subject Property.
32The Appellant’s expert witness testified that larger multi-family residential rental properties in the City of Kingston similar to the Subject Property are owned by a small group of large institutional investors who typically hold these properties for the long-term. He argued that, as a result, there was no corresponding sales data for larger properties similar to the Subject Property.
33Further, the Appellant’s expert stated that properties of different sizes attract different types of investors and may trade at different cap rates. He testified that larger properties sell at higher cap rates, but there was no evidence before the Board to support this view.
The Board’s Analysis
34The Board considered all the properties presented by both MPAC and the Appellant in determining the base cap rate for the Subject Property. Specifically, the Board considered whether the properties were similar to the Subject Property for comparison purposes in this context.
35The Board did not consider properties that were substantially older, had fewer amenities and that were significantly smaller in number of units, building area and land area than the Subject Property to be comparable to the Subject Property for valuation purposes. In addition, many of the properties referred to by both the Appellant and MPAC had significantly different NOIs compared to the Subject Property. For example, of the nine properties provided by both Appellant and MPAC for comparison purposes, seven properties had NOIs less than $150,000, which was approximately one-tenth of the NOI of the Subject Property. Moreover, the lowest NOI was $55,987, where the Subject Property’s determined NOI was substantially more at $1,439,426.
36MPAC also relied on time adjustment factors (“TAF”) to adjust purchase prices to simulate what each property would have sold for as of the valuation date, but the Board rejects the use of TAF in this instance for the two reasons that follow.
37First, MPAC relied on data relating to 174 property sales that occurred in an area including, but also going far beyond the City of Kingston to determine the quantum of its time adjustments. This data arose from sales that occurred in Cornwall, Brockville, and Belleville, without specifically indicating which sales occurred in each of these areas of Eastern Ontario. The Board concurs with the Appellant that this was much too large of an area to give an accurate indication of the appreciation or depreciation in values that occurred in the Kingston real estate market over time.
38Second, the Board previously determined at para. 11 of Sundararaj v. Municipal Property Assessment Corporation, Region 03, 2018 CanLII 104619 (“Sundararaj”) that “time adjustment should never replace sales that took place close to the valuation day” and that “there is no better snapshot of how a housing market is behaving on a particular day than sales in that market near that day.” In its conclusion in Sundararaj in the same paragraph, the Board determined that “time adjustments should only be relied upon where no better evidence is available.” Since there was better evidence available in this instance, the Board rejects MPAC’s time adjustments. The Board made similar determinations in Layton v Municipal Property Assessment Corporation Region 03, 2021 CanLII 26726 at para. 29 and Joubarne and Municipal Property Assessment Corporation, Region 03, 2019 CanLII 22897 at para. 48.
39For those reasons, the Board rejected MPAC’s first property at 655 Princess Street in its analysis because that sale occurred too far from valuation date of January 1, 2016 to be reliable, having sold on September 29, 2017, almost 21 months later. The Board also rejected MPAC’s third sale, 59 Stanley Street and its fourth at 148 Pine Street, as both these properties were significantly smaller than the Subject Property. The Board found that these were not similar, nor comparable to the Subject Property for the purpose of determining cap rates.
40That left a single property in MPAC’s evidence, 1 Mack Street (which in the Appellant’s evidence included municipal addresses 318 and 320 Alfred Street), that the Board found was comparable for the purpose of determining a cap rate for the Subject Property. It was the most similar of MPAC’s properties to the Subject Property in a data set with very few substantially comparable properties to choose from. This property sold in December 2016, within one year of the valuation date of January 1, 2016, with an NOI of $325,116 including property taxes as an expense. The sale price for this property was $6,750,000 and the cap rate for this property based on the actual, i.e. unadjusted sales price was 4.82%.
41Of the five sales provided by the Appellant, the Board rejected its first, 97 &100 Bagot Street with 10 units, its fourth, 73 Fraser Street with 12 units, and its fifth at 204 and 206 William Street, also with only 12 units. MPAC’s expert testified that the Appellant’s fourth property was contaminated and that this impairment was reflected in the sale price. While the Appellant’s expert challenged MPAC’s expert’s testimony on this point, the cap rate for that property was nonetheless an outlier at 8.59% which was otherwise unexplained.
42Further, MPAC’s expert testified that the Bagot Street and William Street properties consisted of two separate properties, each of which was not classified as multi-residential properties because they each had fewer than seven units. In addition, the Appellant’s expert witness testified that the collective Bagot Street properties were across the street from one another and that the William Street properties were, in fact, two houses operating as one. Further, all of these properties were significantly smaller than the Subject Property and were not similar, nor comparable to the Subject Property. Lastly, the Board rejected the Appellant’s third sale, 67 Notch Hill Road, because that sale occurred in August 31, 2018, too far away from the valuation date to be reliable.
43The Board relied on the Appellant’s sole remaining property,14 Vine Street, for comparison purposes in the determination of a cap rate for the Subject Property to be considered with MPAC’s 1 Mack Street property. While significantly smaller than the Subject Property, 14 Vine Street was the largest property sale by number of units of those provided by the Appellant that occurred within one year of the valuation date having sold on April 15, 2016. This property had an NOI of $111,268 and a corresponding sale price of $1,600,000. The base cap rate for this property using the actual sales price was 6.95%.
Finding on Issue 2
44Based on the evidence before it, the Board finds that the appropriate base cap rate for the Subject Property is between 4.82% and 6.95%, which was derived from the respective cap rates for the two properties relied upon by the Board: 1 Mack Street from MPAC’s evidence and 14 Vine Street from the Appellant’s evidence.
45Based on the available evidence and the above analysis, the Board finds that 5.89%, representing the midpoint of the above cap rates, is the appropriate base cap rate for the Subject Property.
46Taking the 5.89% base cap rate and adding the 1.27% property tax rate results in a cap rate for the Subject Property of 7.16%.
47The Board finds that 7.16% is the cap rate to be used in determining the value of the Subject Property.
Issue 3 – Is the direct comparison approach appropriate for valuing the Subject Property?
48In the direct comparison approach, the sale prices of similar properties to the property at issue are used to arrive at a value for that property. As described by the Appellant in its expert report, “the premise [of the direct comparison approach] involves the principle of substitution which maintains that a prudent buyer would not pay more for a property than it would cost to buy an equally desirable substitute property…”
49The Board finds that the direct comparison approach can produce a reliable estimate of market value when a reasonable number of similar properties are regularly bought and sold in the open market, but that was not the case in this instance.
50MPAC argued that this approach is less useful when insufficient market transactions for a given property type are available. In this instance, MPAC conducted a search of sales between 2013 and 2017 of class B multi-residential buildings built in the last 20 years in Kingston West but found no such sales. As a result of this lack of data, MPAC concluded that the direct comparison approach was not useful in these circumstances.
51The Appellant searched for sales of multi-family residential properties between 2015 and 2017 in the City of Kingston. It found five such sales ranging in price per unit from $72,656 to $293,478 applying no time adjustments. The Appellant suggested that adjustments should be made for comparison purposes including for location, land area and density, property condition, number of units and size of units, but did not provide the value differentials that should be applied for those adjustments. The Appellant concluded that all but one of its properties were inferior to the Subject Property and that the Subject Property would sell for 30% more than the highest value of the inferior properties, or 1.3 X $105,000 being $137,000 per unit rounded up from $136,500 per unit.
52The largest of the Appellant’s properties, its third at a collection of municipal addresses, 276 and 296 Conacher Drive, 44, 54, 66, 80 and 118 Virginia Street, consisted of a portfolio of seven separate apartment buildings built in, or around 1977 and 1978, with a total of 202 units. It sold for $21,210,000. Another, its first property at 1 Mack Street and 318 and 320 Alfred Street, consisted of three buildings – a townhouse built in 2013, a Victorian brick house built in 1900 and a purpose-built walk-up apartment building built in 1960 – was too dissimilar from the Subject Property in its physical characteristics to be useful in the direct comparison approach. Its fifth property at 67 Notch Hill Road was built in 1971 and sold in August 2018, well after the January 1, 2016 valuation date. It was also substantially different from the Subject Property, having only 26 units compared to the Subject Property’s 113, and it included only 0.99 acres of land whereas the Subject Property had three times that amount. The Appellant’s second property at 99 Thomas Street was built around 1973, and its fourth at 15 Adelaide Street was built in 1964. All of these were too different from the Subject Property to be useful in a direct comparison analysis.
53There were other significant differences between the Appellant’s properties used in its direct comparison approach and the Subject Property. For example, the land area for these properties ranged from 0.50 to 7.86 acres (for the portfolio of seven properties) compared to the Subject Property’s 2.93 acres; four of the five properties had between 23 and 35 units and one had 202 units (for the portfolio) compared to the Subject Property’s 113 units; the area of improvements ranged from 20,592 square feet to 126,486 square feet (for the portfolio) compared to the Subject Property’s 158,000 square feet. Finally, all but one of the sale properties were in different neighbourhoods than the Subject Property.
Finding on Issue 3
54The Board finds that the properties used by the Appellant in the direct comparison approach were substantially dissimilar to the Subject Property and that they did not provide an accurate “check” to the parties’ use of the income approach for determining value.
Issue 4 - What is the current value of the Subject Property for the 2020 – 2021 taxation years?
55As noted above, calculating the current value of the Subject Property requires dividing the NOI by the cap rate. As the NOI of the Subject Property is $1,439,425 and the applicable cap rate for the Subject Property is 7.16%, the Board determines the current value of the Subject Property to be $20,103,701.
Finding on Issue 4
56The Board finds the current value of the Subject Property is $20,103,701.
Issue 5: Is an equity reduction of the current value required, and if so, how much?
57Section 44(3)(b) of the Act directs that after determining current value, the Board shall have reference to the value at which similar lands in the vicinity are assessed and adjust the assessment of the land to make it equitable with that of similar lands in the vicinity if such an adjustment would result in a reduction of the assessment of the land.
58The Assessment to Sales Ratio (“ASR”) is a tool used to determine whether a reduction of the assessment is required to make it equitable with the assessments of similar lands in the vicinity. The ASR is determined by dividing the assessment as returned by the time-adjusted sale price.
59Both parties took the position that an equitable reduction was required and submitted evidence of property sales to support their analyses. MPAC provided data on 32 sales that occurred between 2014 and 2017 in the City of Kingston to support its position that an equitable reduction of 6.5% was required based on a median ASR of 0.935. The Appellant provided data on nine properties that sold that between 2016 to 2018 and took the position that an equitable reduction of 14% was required based on a median ASR of 0.86. Of the properties submitted by both the Appellant and MPAC, five were in common.
The Board’s Analysis
TAFs
60MPAC applied TAFs in its equity analysis to approximate what each of its properties would have transacted for as of the valuation date of January 1, 2016. The Appellant did not apply any TAFs.
61Earlier in this decision when considering cap rates, the Board rejected MPAC’s use of TAFs because it considered property sales outside of the City of Kingston and because there was better evidence available that did not require their application. The Board rejects their use in the equity analysis for the same reasons. Instead, the Board relied only on those sales that took place during the shoulder years of the valuation date, in other words, the one-year period before and after January 1, 2016. The sales considered, therefore, must have occurred between January 1, 2015 and December 31, 2016.
62The Appellant’s expert witness took the position, however, that sales which took place in 2017 should also be considered because that year was also a shoulder year. This was relevant to only one of the Appellant’s properties in its equity analysis, 56 Lansdowne Street, which transacted on June 19, 2017.
63If the Board were to accept that submission, its analysis would lack balance because it would be considering transactions two years after the valuation date but only one year prior to it. The Board finds the shoulder years to be one year on either side of the valuation date as it did in Hopkins v. Municipal Property Assessment Corporation, Region 32, 2021 CanLII 74739 at para. 13, where it determined that shoulder years are “12 months on either side of the valuation date.” No alternative approach was necessary in these circumstances.
Similarity
64In order to identify ‘similar’ properties for equity analysis purposes, the Appellant’s expert included only those properties in the City of Kingston that sold for over $1,200,000 and contained 10 or more units. The Board accepts this characterization for equity analysis purposes. While MPAC did not provide numbers of units, the Board applied the greater than $1.2 million filter to MPAC’s list. It also excluded portfolio sales which were not sufficiently similar to the Subject Property to be of use in an equity analysis.
65As such, the Board considered all properties submitted by both the Appellant and MPAC that were not portfolio sales and that sold for more than $1.2 million in either 2015 or 2016, one year on each side of the valuation date. This resulted in a combined list of 12 properties. The 12 properties had ASRs (unadjusted for time) ranging from 0.84 to 1.1 with a median ASR of 0.92 as shown below:
Property Sales > $1.2 million; in 2015 or 2016
| Source | MPAC # | App # | Address | Assessed Value ($) | Sale price (no TAF) ($) | ASR |
|---|---|---|---|---|---|---|
| MPAC | 8 | 148 Pine St. | 1,373,000 | 1,641,000 | 0.84 | |
| MPAC/Appellant | 10 | 2 | 14 Vine St. | 1,375,000 | 1,600,000 | 0.86 |
| MPAC/Appellant | 13 | 3 (in part) | 118 Virginia St. | 3,769,000 | 4,325,760 | 0.87 |
| 15 | 66 Virginia St. | 2,986,000 | 3,360,000 | 0.89 | ||
| 16 | 54 Virginia St. | 1,703,000 | 1,856,000 | 0.92 | ||
| 17 | 80 Virginia St. | 2,275,000 | 2,475,600 | 0.92 | ||
| 18 | 44 Virginia St | 3,826,000 | 4,126,260 | 0.93 | ||
| 19 | 51 Stanley St. | 1,373,000 | 1,480,000 | 0.93 | ||
| MPAC/Appellant | 22 | 1 | 15 Adelaide St. | 2,353,000 | 2,325,000 | 1.01 |
| MPAC/Appellant | 24 | 6 | 99 Thomas St | 2,625,000* | 2,600,000 | 1.01 |
| 29 | 475 Palace Rd. | 1,430,000 | 1,300,000 | 1.10 | ||
| Appellant | 7 | 204-206 William St. | 1,312,000 | 1,350,000 | 0.97 | |
| Median | 0.92 |
*Assessed value for 99 Thomas St is after a reduction in the assessment from $3,056,000 as shown in MPAC’s equity analysis.
Finding on Issue 5
66The Board finds that similar properties in the vicinity have not been assessed at or near their current values and that an equitable reduction to the current value of the Subject Property of 8% is required.
CONCLUSION
67The Board finds that the current value of the Subject Property is $20,103,701.
68The Board finds that an equitable adjustment is warranted and that the ASR of 0.920 should be applied to the correct current value of $20,103,701 to reduce it to $18,495,405 or $18,500,000 rounded.
ORDER
69The Board orders that the current assessed value of the Subject Property be reduced from $20,115,000 to $18,495,405, rounded to $18,500,000.
"Christopher Voutsinas"
CHRISTOPHER VOUTSINAS VICE-CHAIR
"Jean-Paul Pilon"
JEAN-PAUL PILON MEMBER
Assessment Review Board Website: www.tribunalsontario.ca/arb