Sutton-53rd Corp. v. Tax Commission

I dissent and would reverse the order of the Special Term which granted respondent tax exemption on a building (in course of construction) for the tax year 1952-53. The exemption was allowed on the ground that there had been no construction, as contemplated by the statute (Administrative Code of City of New York, § 157-1.0) prior to January 25, 1951. That is the significant date in this case, for if construction was started prior thereto, the exemption was improper.

The sole question therefore is whether what was done by respondent in advancement of the project, prior to January 25, 1951,…