In New York Tel. Co. v. Supervisor of Town of Oyster Bay (4 N.Y.3d 387, 828 N.E.2d 964, 796 N.Y.S.2d 7 [2005]), the Court considered whether mass property owned by New York Telephone Company (NYTC) (specifically, telephone lines, wires, cables, poles, supports and enclosures for electrical conductors) constituted "benefited" property upon which the Town of Oyster Bay could impose a special ad valorem levy for garbage collection. The Court held that "for real property to be 'benefited,' it must be capable of receiving the service funded by the special ad valorem levy" (4 N.Y.3d at 393). To determine whether property is "capable of receiving the municipal service" funded by the tax, "we look to the innate features and legally permissible uses of the property, not the particularities of its owners or occupants or the state of the property at a fixed point in time" (id. at 394). Thus, we concluded that NYTC's real property--consisting solely of equipment situated on or under public and private land not owned by NYTC--was not and could never be benefited by the garbage district because "telephone poles can never produce or require municipal garbage collection" (id.).