[brief] Demonstrating the Board’s Arbitrary and Capricious Determination of [...]’s Equity in the Unit  [...] purchased the Property in 1993 as an eleven-unit apartment building for $525,000.00.  Da 37; 1T:13-19.  The pro rata purchase price for the Unit was $47,727 ($525,000/11 units).  The Unit occupies approximately 1,000 square feet, which is approximately 10% of the building.  In 2002, [...] invested $1 million in the building for renovations to the apartments and common areas.  7T:38:8-38:24.  The Unit specifically received $76,900.00 of capital improvements.  1T:6:14-16, 44:10-16, 5T:74:12-25  That sum, set forth in [...]’s Certification submitted with [...]’s application, and supported by [...]’s testimony, is undisputed.  Moreover, there is no basis in the record (or law) to dismiss the capital improvements to the Unit based upon their age, as the Board did.  Capital improvements demonstrate real dollars invested by [...] in the Unit.  Just as the purchase price for the Unit in 1993 is not nullified by age, neither are capital improvements.  Both the purchase price, plus capital improvements, irrespective of their age, comprise [...]’s equity in the Unit, adjusted for inflation.  [...]’s assessment for the Unit in 2017 was $404,600.00, and application of the municipal equalization ratio of 74.18% resulted in an equalized fair market value of $545,483.  The appraised market value of the Unit was $622,500, as set forth in an appraisal submitted by [...] to the Board and testified to by [...], [...]’s valuation expert.  Notably, although ultimately the appraisal was not used by [...] to calculate its equity in the Unit, it demonstrates that [...]’s equity in the Unit was substantially less than its appraised value.  [...] established that, in adjusting its $47,727 purchase price for the Unit and its $76,900 capital improvements to the Unit for inflation based upon the CPI over the period 1993-2017, the Unit’s value is $197,600.  No record facts support the Board’s determination that [...]’ equity in the Unit is only $12,804.88.  As previously stated, the Board, through its chairwoman, contrived an irrational formula of comparing assessments and then using arbitrary unsupported numbers to further reduce equity—for the benefit of [...].  The Board’s chairwoman compared assessments and tax payments without considering the equalization ratio and then arbitrarily determined that the Unit has a value of 25% of the other units before then further dividing that value by 41% to reach $12,804.88 of equity.  See 10T:168-182.  The Board protected [...], who was known to them, by fabricating a hardship increase based neither on record evidence nor the requirements of law, including its Ordinance.  The Board contrived a rent increase acceptable to [...] by arbitrarily reducing [...]’s equity to a negligible amount and disallowing routine expenses paid by [...].  [...]’s monthly rent increased from $675 to $723.41 over a 28-year period between 1993 and 2021 when the Board granted the $154.99 hardship increase that [...] seeks to defend.  Da 36; 1T:33:25-34:1, 1T:47:27-48:1, 7T:89:20.  The Board’s ruling on [...]’s equity in the Unit deprives [...] of any “fair return” and forces [...] to continue to subsidize the Unit and lose thousands of dollars every year for as long as rent control protects [...].  B.