Town of Tonawanda v. Ayler
| Decision Date | 09 October 1986 |
| Citation | 500 N.E.2d 869,508 N.Y.S.2d 171,68 N.Y.2d 836 |
| Parties | , 500 N.E.2d 869 TOWN OF TONAWANDA et al., Appellants, v. Merilyn H. AYLER et al., Respondents. |
| Court | New York Court of Appeals Court of Appeals |
The order of the Appellate Division, 115 A.D.2d 940, 497 N.Y.S.2d 781, should be affirmed, with costs.
As we have many times declared, classifications made by taxing statutes do not require precise, scientific uniformity, are presumed constitutional, and will be upheld if rationally related to a legitimate governmental purpose and though uneven in application are not palpably arbitrary (Trump v. Chu, 65 N.Y.2d 20, 489 N.Y.S.2d 455, 478 N.E.2d 971; Foss v. City of Rochester, 65 N.Y.2d 247, 491 N.Y.S.2d 128, 480 N.E.2d 717; Matter of Long Is. Light. Co. v. State Tax Commn., 45 N.Y.2d 529, 410 N.Y.S.2d 561, 382 N.E.2d 1337).
Here there can be no question that the differentiation between owners of one-, two- and three-family residences and other property owners is rationally related to a legitimate governmental purpose. As noted in the sponsor's memorandum and in the Governor's approval message, prior to enactment of title 1-A of the Real Property Tax Law the procedure for review of tax assessments was so complex and expensive as to be prohibitive for the owners of such properties, thus imposing upon them an undue burden (1981 N.Y.Legis.Ann., at 528-529).
Nor can it be said that the classification results in a differentiation that is arbitrary. It establishes a small claims procedure which is limited to those seeking a reduction not in excess of $750 (RPTL 730), and while it provides for the preparation by the State Board of Equalization and Assessment of a residential assessment ratio (RPTL 738) which is not used in other than small claims review proceedings, the same data may be presented by taxpayers involved in such other proceedings. Just as the restriction in Matter of Colt Indus. v. Finance Administrator, 54 N.Y.2d 533, 446 N.Y.S.2d 237, 430 N.E.2d 1290 based on population and geographic area was not violative of equal protection, so also the differentiation between the owners of one-, two- and three-family residential property and other property owners is not....
To continue reading
Request your trial
-
Supreme Associates Llc v. Suozzi
...of New York, supra, 54 N.Y.2d at 544, 446 N.Y.S.2d 237, 430 N.E.2d 1290 [citations omitted] see also, Town of Tonawanda v. Ayler, 68 N.Y.2d 836, 838, 508 N.Y.S.2d 171, 500 N.E.2d 869 [1986]; Matter of Tolub v. Evans, 58 N.Y.2d 1, 8, 457 N.Y.S.2d 751, 444 N.E.2d 1 [1982] ). Further, and as p......
-
Krugman v. Board of Assessors of Village of Atlantic Beach
...unequal treatment bear a rational relation to the achievement of a legitimate governmental purpose (see, Town of Tonawanda v. Ayler, 68 N.Y.2d 836, 837, 508 N.Y.S.2d 171, 500 N.E.2d 869; Foss v. City of Rochester, 65 N.Y.2d 247, 491 N.Y.S.2d 128, 480 N.E.2d 717; Trump v. Chu, supra). Distin......
-
Prodell v. State
...of a legitimate State purpose." Trump v. Chu, 65 N.Y.2d 20, 25, 489 N.Y.S.2d 455, 478 N.E.2d 971; Town of Tonawanda v. Ayler, 68 N.Y.2d 836, 837, 508 N.Y.S.2d 171, 500 N.E.2d 869. Moreover, "there is a strong presumption that statutes are constitutional, such that 'unconstitutionality must ......
-
W.J.F. Realty Corp. v. Town of Southampton
...contention that the Town's conduct was not in furtherance of legitimate governmental objectives (see, Town of Tonawanda v. Ayler, 68 N.Y.2d 836, 508 N.Y.S.2d 171, 500 N.E.2d 869; Abberbock v. County of Nassau, 213 A.D.2d 691, 624 N.Y.S.2d 446; Kasper v. Town of Brookhaven, 142 A.D.2d 213, 5......