County of Erie v. City of Buffalo

4 A.D.2d 319, 165 N.Y.S.2d 365, 1957 N.Y. App. Div. LEXIS 4773

This text of 4 A.D.2d 319 (County of Erie v. City of Buffalo) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
County of Erie v. City of Buffalo, 4 A.D.2d 319, 165 N.Y.S.2d 365, 1957 N.Y. App. Div. LEXIS 4773 (N.Y. Ct. App. 1957).

Opinion

Bastow, J.

This appeal presents the question as to whether the City of Buffalo or the County of Erie has the right to impose a local tax upon transactions whereby third parties within the city purchase and consume gas, electricity, steam and refrigeration. Since 1947 the county has imposed and collected, presumably for educational purposes, a sales tax at the rate of 1% on tangible personal property, and at least since 1948 has taxed, as such property, the sale of gas, electricity, steam and refrigeration. In 1954 the city adopted a local law imposing, among other things, a 2% tax on consumers’ bills for the same utilities. The parties to this action for two years thereafter operated under a written agreement by the provisions of which the combined sales tax of 1% and consumers’ utility tax of 2% were collected by the county and divided on the basis of one third to the county and two thirds to the city. In 1956, however, the city enacted a local law imposing upon consumers’ utility charges a tax of 3%, which [321]*321is the maximum amount that may be imposed thereon by one or more municipalities whether in the form of a utility tax or jointly as sales and utility taxes.

The county brought this action seeking a judgment declaring that it has a prior right to impose a 1 °¡o tax on the sales of these articles and invalidating so much of the city’s local law as attempts to impose a utility tax in excess of 2%. The city by its answer seeks relief in similar form decreeing that it has the prior right to impose the full tax of 3% and asks that the county be restrained from collecting any sales tax on such transactions.

The contentions of the parties require a brief resume of the enabling statutes. In 1947 the Legislature authorized counties, outside of the city of New York, for educational purposes only, to adopt local laws imposing certain types of nonproperty taxes. One of these was a sales and compensating use tax at a rate not to exceed 2%. At the same time cities, within stated population limits, were authorized to impose certain specified nonproperty taxes and any of the taxes the county was empowered to levy “ during such time as and to the extent that the county within which such city lies does not impose such tax.” The statute went on to set up procedures to be followed by a county if it desired to preempt an area of taxation then occupied by a city. (L. 1947, ch. 278, §§ 1, 2.) The statute further provided in section 8 that moneys collected from taxes by a county should be paid to the several school districts therein while section 9 authorized a city to use the moneys collected for any city purpose.

Significant amendments were made to the enabling act in 1948 (ch. 651). A provision was inserted in section 1 defining the expression tangible personal property” as used in the sales tax to include gas, electricity, steam and refrigeration. A new maximum 3% utility consumption tax was authorized by subdivision (c) of section 1. Since these amendments made it possible for both a sales tax and a consumers’ utility tax to be imposed upon the same transaction there was for the first time the possibility of multiple taxation. Accordingly, the final sentence of subdivision (c) of section 1 provided (and still provides) that “ If a tax is also imposed on any of the foregoing pursuant to paragraph (a) of this section, [the sales tax] the tax rates shall be adjusted as provided in section four of this act.”

Thus, if a county imposed both a sales and a utility consumption tax upon the same transaction, section 4 came into play and it provided in part: “ No transaction, which, as used in this [322]*322paragraph, shall include any privilege or use, shall be taxed pursuant to this act by any county or by any city located therein, or by both, at an aggregate rate in excess of the highest rate fixed by any single paragraph of section one. If a transaction is taxed by both a county and a city, the city tax rate on such transaction shall be deemed to be reduced (or the entire tax eliminated, if necessary) to the extent necessary to comply with the foregoing requirement.”

This 1948 enactment continued the provision authorizing certain cities to impose the sales tax and other taxes authorized by section 1 but all of this was “ subject to the provisions of section four ” the pertinent portion of which has been heretofore quoted. Two observations should be made as to these provisions. First, where the same tax was levied by a county and a city contained therein, the county tax pursuant to section 4 had absolute priority and second, the last sentence of subdivision (c) of section 1 mandating an “adjustment” of the tax, if multiple taxation resulted from imposition of the sales tax and the consumers’ utility tax, was not designed to raise any question of priority. In other words, as the law then stood, there could be no such question, because any conflict between a city tax and a county tax by mandate of the statute was reconciled in favor of the latter. On the other hand, if either municipality attempted to impose two. taxes (sales and utility consumption) at a collective rate in excess of 3%—the highest rate permitted by any single subdivision of section 1—then each rate would be reduced or adjusted to comply with section 4. If, however, both city and county attempted to impose a multiple tax in excess of the collective rate there would be no “ adjustment ”. By the plain language of section 4, in such a case the rate imposed by the city would be “ reduced ” or “ eliminated, if necessary” while the county tax, supported by an absolute priority, would remain unchanged.

Two years later this statute was radically changed. This was brought about through studies made by the State Comptroller’s Committee on Local Non-Property Taxes appointed by that official in November, 1949. The work of the committee culminated in a written report recommending legislation in 10 different areas of this field of taxation. We are here concerned with recommendation numbered six. After reviewing the then provisions of the law providing that a county might pre-empt a tax which was being imposed by a city it was stated that the purpose of the recommendation was to give cities and counties the right to impose certain nonproperty taxes with assurance that the other unit would not pre-empt the tax. [323]*323Insofar as we are here concerned it was specifically recommended (Report, March 6> 1950, p. 9) as follows: “ A. Counties be given prior right to tax (1) motor vehicle use, (2) privilege of selling alcoholic beverages at retail, and (3) coin operated amusement devices; B. Cities be given prior right to tax (1) restaurant charges of one dollar or more, (2) consumers’ utility bills, (3) admissions, and (4) hotel room occupancy; C. Counties and cities each be given a prior right to one half of the rate of the retail sales and business privilege taxes for their own purposes.”

The following year the Legislature implemented these recommendations (L. 1950, ch. 589). Section 4 was amended to provide in part that “No transaction, which, as used in this paragraph, shall include any privilege or use, shall be taxed pursuant to this act by any county or by any city located therein, or by both, at an aggregate rate in excess of the highest rate fixed by any single paragraph of section one of this act.

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4 A.D.2d 319, 165 N.Y.S.2d 365, 1957 N.Y. App. Div. LEXIS 4773, Counsel Stack Legal Research, https://law.counselstack.com/opinion/county-of-erie-v-city-of-buffalo-nyappdiv-1957.