Low Stamford Corp. v. Stamford

In Low Stamford Corp. v. Stamford, 164 Conn. 178, 319 A.2d 369 (1972), the Court had occasion to interpret 12-81a, which covers the situation reciprocal to that involved here, namely, the purchase of property by a taxable entity from an entity exempt from taxation. In that case, in which the plaintiff purchased the property at issue from an exempt entity, the Supreme Court stated that "the assessed value of the property as of September 1, 1968, should be prorated from August 29, 1969, [the date the plaintiff acquired title] to September 1, 1969." 164 Conn. at 184. In that case, the court interpreted the language of 12-81a, which required the nonexempt purchaser of tax exempt property to pay "a prorated share of taxes for the tax year in which the transfer took place." The Supreme Court affirmed the trial court's interpretation of the words tax year to mean assessment year rather than the city's fiscal year. 164 Conn. at 183-184. That court determined that the taxes for the assessment year should be apportioned on the basis of the acquisition date. The plaintiff was liable pro rata for taxes as assessed on the property for the period covering the date of acquisition to the new assessment. 164 Conn. at 184-85. The Supreme Court interpreted the reference to tax year as meaning the period of time that runs from assessment date to assessment date, rather than the city's fiscal year.