Taxpayer, an organization that provided health and social services to elderly people, appealed decision from city tax board of assessment review, which denied taxpayer’s appeal seeking property tax exemption from city tax assessor, claiming its property qualified for exemption under statute providing exemptions for property held for aid or support of aged poor.
The Superior Court granted tax assessor’s cross-motion for summary judgment and denied taxpayer’s motion for summary judgment. Organization appealed.
The Supreme Court held that taxpayer was not entitled to tax exemption under statute providing exemptions for property held for aid or support of aged poor, specifically, for property held for, or by, incorporated library, society, or any free public library.
Statute providing exemptions for property held for aid or support of aged poor, specifically, for property held for, or by, incorporated library, society, or any free public library, or any free public library society, so far as property is held exclusively for library purposes, or for aid or support of aged poor, or poor friendless children, or poor generally, or for nonprofit hospital for sick or disabled, was ambiguous as it applied to taxpayer, an organization that provided health and social services to elderly people, and thus taxpayer was not entitled to property tax exemption; in one reading, term “society” was open in nature, allowing for many entities to receive tax exemption, and other reading would limit “society” to one that was connected to library in some manner, given its inclusion amongst several library entities.