Hellerstein v. Assessor of Islip

I think the order of the Appellate Division should be affirmed.

While the long-standing practice of fractional assessments for real property taxation cannot be said to violate the constitutional mandate that "[assessments shall in no case exceed full value” (NY Const, art XVI, § 2), there can be no blinking the fact that fractional assessment cannot be squared with the literal command of section 306 of the Real Property Tax Law —"All real property in each assessing unit shall be assessed at the full value thereof.”

Were we now called on to interpret such a provision in a recently adopted…