Long Island Lighting Co. v. State Tax Commission

OPINION OF THE COURT

Jones, J.

We hold that the New York City mortgage recording tax; with respect to a mortgage covering real property located both within and without the city was properly determined by the State Tax Commission on the basis of the relative assessments of such property as they appeared on the respective assessment rolls, without adjustment for differences in equalization rates.

On December 23, 1971 petitioner (LILCO) recorded in the Nassau County Clerk’s office a $50,000,000 supplemental indenture to a mortgage previously executed by it on its properties located in the Counties…