Landlord Didn't Need to Itemize Improvements

Tenant complained of a rent overcharge. Landlord claimed that it performed improvements costing $20,000 to tenant's apartment before tenant moved in. The DRA ruled for tenant, finding some overcharge. The DRA allowed a rent increase, based on $15,000 worth of landlord's claimed costs, but disallowed the remaining $5,000. Both landlord and tenant appealed. The DHCR ruled for landlord. Landlord never itemized the costs of the improvements made to tenant's apartment. But since tenant didn't argue that the improvements weren't made, landlord wasn't required to itemize them. And DHCR Policy Statement 90-10 concerning individual apartment improvements doesn't require an itemized list of costs or more than one type of proof of improvements. Landlord's checks to its contractor were made at the time the work was done and matched the cost stated on the work proposal.

Park Towers South Co./Huderski: DHCR Admin. Rev. Dckt. Nos. KB410019RP, JC410337RO, JC410170RT (4/12/96) [7-page document]