Rochester Housing Authority v. Sibley Corp.

The decisive issue is whether the Rochester Housing Authority is exempt from the payment of real estate taxes on property acquired after the taxable status date, but before the date taxes were levied and became a lien.

Section 302 of the Real Property Tax Law provides that the taxable status of real property shall be determined annually as of a certain date and that real property “ shall be assessed * * * according to its condition and ownership as of such date.” Ordinarily, therefore, exemptions are determined on the basis of ownership on the taxable status date, and real property not…