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Environmental Health - Public
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3500 - Local Oversight Program
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PR0545864
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SITE INFORMATION AND CORRESPONDENCE
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Last modified
7/21/2020 9:08:54 AM
Creation date
7/21/2020 8:47:13 AM
Metadata
Fields
Template:
EHD - Public
ProgramCode
3500 - Local Oversight Program
File Section
SITE INFORMATION AND CORRESPONDENCE
RECORD_ID
PR0545864
PE
3528
FACILITY_ID
FA0004530
FACILITY_NAME
MARLOWE PROPERTY
STREET_NUMBER
4648
STREET_NAME
WATERLOO
STREET_TYPE
RD
City
STOCKTON
Zip
95215
CURRENT_STATUS
02
SITE_LOCATION
4648 WATERLOO RD
P_LOCATION
99
P_DISTRICT
002
QC Status
Approved
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M <br /> i <br /> Page 3 . <br /> application instructions reflects this! dislinction when it <br /> states that gross revenue is to be documented by "the <br /> appropriate IRS tax forms. " The appropriate tax forms in a <br /> sole proprietorship company, which MarloweProperties is , are <br /> the Schedule E (which is used for a company earning income <br /> from rental properties , rather than Schedule C, the Business <br /> Income tax form) . Our Schedule E clearly °documents a total <br /> gross revenue over the past 3 years of�[ $2 ,'931, 617 . , which <br /> falls , per se, below the $3 , 000,000 limit of the Small <br />` Business Category "Service ix. 1" whichlwasladopted by the <br /> li Fund and should therefore place us in Priority Class B. Only <br /> by including -other personal (non-busiriess )irincome derived <br /> from sources other than the company, Marlowe, Properties , is <br /> the Fund able to arrive at their determination that the gross <br /> f revenue limit ($3M/3yr) has been excee;4ed,land even then <br /> only by a very small dollar amount. <br /> The alternative second basis of our appeal challenges the <br /> make up of the category into which the'! Fund has placed us. In <br /> order to be eligible for placement in the Priority Class B <br /> classification, we must be certified as a �M"small business" <br /> according to specific maximum allowable annual receipts which <br /> are determined by the category of businessIwhich best- <br /> describes <br /> estdescribes our particular business . We1have repeatedly stated <br /> that the Fund incorrectly modified an existing category and <br /> placed our business in that category. JjIn order to correct <br /> this misassignment, whichenalt an unfair <br /> laces ' <br /> P ,j ;� F Y by <br /> applying inappropriately low gross receipts limits on our <br /> type of business , the Fund should create al <br /> new cateogry which <br /> accurately reflects the nature and fiscal structure of "Real <br /> Estate Owners/Operators"(our type of business ) . <br /> When the Fund was initially formed and preliminary <br /> applications were mailed, our, type of business . :through <br /> oversight. . . had been omitted altogether ( see Exhibit E) . <br /> When we then asked the Fund about how bur business would be <br /> categorized, the Fund's program analyst advised us that they <br /> were working on creating a proper categorization. The Fund <br /> then became aware that them was some difficulty in finding a <br /> ipre-existing OSMB category to fit our busi1hess . To solve <br /> this problem they modified an existing'! category by adding <br /> "Real Estate Operators" (their attempt.,.to ;categorize our type <br /> of business ) to the category "Service x. 2�' , which prior to <br /> this modification had only included: `Accountants, Auditors , <br /> Appraisers and Business Services" to which� a $3 Mil , 3 year <br /> gross receipts limit was assigned ( see'lExhibit E & F) . In <br /> the Final Staff Decision a disengeni.ous position is taken F <br /> when they acknowledge creating this category and then state <br /> "we made an error"in creating it. In turn; our position is <br /> that the only error they actually made wasirthe inclusion of h <br /> our company with a category of businesses with which our <br /> business has little in common. II <br />
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