Modern fantasy owners might be standing on the shoulders of giants, but to extend the metaphor, it means their heads are higher than those giants.
LOTR could be overrated as a piece of fantasy writing for a modern audience, even if it is absolutely key to establishing the modern fantasy genre. For me, LOTR was good, but it was unsatisfying in some ways. Like, Gandalf and Saruman were obviously powerful "wizards", but what is it that they could do? How did their powers work? And there were characters like Tom Bombadil who were confusing and had me flipping pages.
I greatly respect Tolkien's work. But, unlike some more modern authors, I don't devour everything he wrote. For example, I absolutely couldn't read the Silmarillion.
So, yeah, I can see how someone would say that LOTR is overrated, even if it was key to establishing an entire genre.