Four Units Are Horizontal Multiple Dwelling

Tenant of a two-unit building claimed that he was rent controlled. The DRA ruled for tenant, finding that the building was connected to another two-unit building. So the four units combined were a horizontal multiple dwelling, subject to rent control. Landlord appealed, claiming that the buildings weren't a horizontal multiple dwelling because they shared only common ownership, management, and heating system. The DHCR ruled against landlord. Under rent control, common ownership, management, and heating were enough to make the buildings a horizontal multiple dwelling in 1968, when tenant moved in.

Szilvassy: DHCR Admin. Rev. Dckt. No. BD110582RO (10/19/01) [4-pg. doc.]