Polly's Properties, LLC v. Department of Taxes

Johnson, J.,

¶ 13. dissenting. The fundamental inquiry at the heart of statutory interpretation is to ascertain the plain meaning of a statute’s words in light of its legislative purpose. Today, the majority ignores this tenet of judicial review in favor of an approach that first infuses ambiguity into an unambiguous statute and then tasks this Court with rewriting the tax-exemption provision under 32 V.S.A. §9603(24) to ease the burden that compliance with the deadline imposes on taxpayers. Because I agree with the trial court that a transfer of property to a limited liability company (LLC)…