at 209-10. Texas Eastern was viewed as having restored the institutional doctrine because the decision stated that if real estate is special purpose property, “the operation of the structure and the operation of the business conducted therein merge.” Id. at 211. The court had reasoned that the Legislature’s intent in enacting Chapter 117 was to broaden the meaning of real property and narrow that of personal property. Ibid. In response to Texas Eastern’s understanding of Chapter 117, the pendulum began to shift toward including business personal property as taxable real property. The Legislature expressed concern with three decisions referred to in our opinion in R.C. Maxwell, supra, 145 N.J. at 563, 679 A.2d 141. See American Hydro Power Partners v. Clifton, 11 N.J.Tax 12 (Tax 1990) (<HOLDING>), aff'd in part, 12 N.J. Tax 264
holding that plaintiffs may have a property interest in real property holding batch ester plant machinery real property holding hydroelectric power machinery real property holding that forfeiture of real property may be adjudicated before the seizure occurs because real property cannot abscond holding that a tax appeal on real property is a lien on the real estate and not a personal obligation of the landowner