Forward v. Webster Central School District

*481OPINION OF THE COURT

David 0. Boehm, J.

This case deals with yet another fiscal lifeboat capsized in the wake of hurricane Hellerstein (Matter of Hellerstein v Assessor of Town of Islip, 37 NY2d 1) and the fruitless legislative efforts which followed it. The history of Real Property Tax Law article 19 is by now too well known to need retelling, except as it applies here.

After the Legislature, in 1981, enacted a new Real Property Tax Law § 305 permitting fractional assessments at a uniform percentage of value and article 19 permitting a city or town to adopt a dual rate tax structure after first…