Florida-based developer Glenn Straub is suing the state of New Jersey for what he described as an unfair imposition of property tax on the shuttered Revel Casino Hotel.

The Press of Atlantic City reported that Straub questioned New Jersey’s PILOT program before the Atlantic County Superior Court on October 14, as he complained that the state sent him a tax bill with $3 million excess.

“It’s crazy,” Straub said of the PILOT, according to the news report. “It’s not a casino, because the state says we need a license. They are penalizing us millions and millions of dollars.”

Under the New Jersey’s casino payment in lieu of taxes (PILOT) program, casinos will have to shell out $120 million this year instead of property taxes. The program was intended to bring balance to the wobbly New Jersey’s tax collection base amid left and right casino tax appeals.