The Second District Appellate Court recently addressed whether buildings, structures, and improvements at a golf club should be considered “open space” for property tax assessment purposes. In Onwentsia Club v. Property Tax Appeal Board, the Court reversed earlier decisions by the Lake County Board of Review and the Property Tax Appeal Board (PTAB) that had denied the open space classification for improved areas of the Onwentsia Club and remanded the case for a factual determination of whether the improvements at the Club “conserve a landscaped area.” Given that open space properties are generally assessed by County officials at a consistent, county-wide market value below that of improved properties, the result of reclassifying the improved areas of the Onwentsia Club as open space would result in significant property tax refunds.

The Onwentsia Club is a private golf club located on approximately 180 acres of land in Lake Forest. Most of the property consists of an 18-hole golf course, but approximately nine acres is improved with a clubhouse, swimming pool, horse riding area, stable, parking lot, driveways, and tennis courts. Prior to 2006, these improved areas of the Club were assessed as open space at a market value of $1,000 per acre. In 2006, the Lake County Assessor’s Office changed the classification of the improved areas to residential property. The result of this change in classification was a dramatic increase in the assessed value of the property. After both the Lake County Board of Review and the PTAB refused to change the classification of the improved areas back to open space, the Club brought the issue before the Appellate Court. The issue presented was whether the property should be granted the open space classification even though it contains improvements.