Throughout New York City, rent-stabilized apartments are being rented to non-corporeal entities, such as corporations and not-for-profit organizations. These apartments, for example, may be used to house an identified corporate officer, or, in the case of not-for-profit organizations, to house a revolving series of persons affiliated with the entity. This article will discuss the rights of owners and non-corporeal tenants under the RSL.

‘Cale Development’

Matter of Cale Dev. Co. v. New York City Conciliation & Appeals Bd. (94 AD2d 229 [1st Dept. 1983], affd 61 NY2d 976 [1984]), concerned an apartment that had been rented to a corporation for the occupancy of its president and his wife. The husband and wife never lived in the apartment, although their son did. The Court of Appeals, affirming the First Department, granted possession to the landlord. The court held that the intended occupants did not use the apartment as their primary residence, and that the corporate tenant was not entitled to a renewal lease.