Greenwich Retail, LLC v. Greenwich

Supreme Court of Connecticut·Decided August 18, 2026·No. SC21167·Published

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GREENWICH RETAIL, LLC v. TOWN OF GREENWICH (SC 21167) Mullins, C. J., and McDonald, D’Auria, Ecker, Alexander, Dannehy and Bright, Js.

Pursuant to statute ((Rev. to 2019) § 12-63c (a) and (d)), a municipal tax asses- sor, in appraising real property used primarily for the purpose of generating rental income, is authorized to require the owner of such property to submit to the assessor certain rental income and expense information relating to the property “on a form provided by the assessor,” and the property owner’s failure to do so “shall be subject to a penalty equal to a ten per cent increase in the assessed value of such property . . . .”

The plaintiff property owner had appealed to the trial court from the deci- sion of the defendant town’s board of assessment appeals, which upheld the imposition of a penalty on the plaintiff, pursuant to § 12-63c (d), for the plaintiff’s failure to timely submit a form, prescribed by the town’s assessor, containing income and expense information related to the plaintiff’s rental income producing property located in the town. The assessor had mailed, in April 2020, to the plaintiff’s last known address, both a demand for the submission of income and expense information and the form on which the information was to be entered. The plaintiff had changed its address in 2016, but there was no evidence that the plaintiff had informed the assessor directly about this change at that time. The plaintiff ultimately did not receive the April 2020 mailing. In June 2020, however, the assessor sent a tax bill to the plaintiff’s last known address, and the business then located at that address forwarded the bill to the plaintiff’s new address. At that point, the plaintiff, through its agent, emailed the assessor and asked the assessor to update the plaintiff’s address. On August 3, 2020, the assessor mass mailed a reminder notice to property owners who had failed to comply with its earlier April 2020 demand, including the plaintiff at its new address. The remainder notice did not include the form the assessor was seeking but directed property owners to retrieve the form from the town’s website. The plaintiff’s agent did not open the mail containing the reminder notice until August 24, 2020, seven days after the August 17, 2020 deadline for submission of the form. The trial court rendered judgment for the town, and the plaintiff appealed to the Appellate Court, which affirmed the trial court’s judgment, concluding that the assessor had satisfied the requirements of § 12-63c by mailing the demand and form to the plaintiff’s last known address and that the statute did not require that the plaintiff actually receive the form. The plaintiff, on the granting of certification, appealed to this court, claiming that the Appellate Court had incorrectly determined that the assessor had satisfied the requirements of § 12-63c because the phrase “on a form provided by the assessor” required actual receipt of the form by the property owner. Held: Greenwich Retail, LLC v. Greenwich

The Appellate Court correctly determined that the assessor had satisfied the requirements set forth in § 12-63c when, in April 2020, it mailed the form to the plaintiff’s last known address.

After reviewing the relevant statutory language, related statutes, and the legislative history of § 12-63c, this court concluded that, when a municipal tax assessor mails the form for rental income and expense information to the last known address provided by the property owner, the assessor fulfills his or her obligation pursuant to § 12-63c (a), as the most plausible construction of the term “provided” in the statute is that the assessor must make the form available to the property owner by reasonable means, and the statute did not require actual receipt of the form by the property owner.

Accordingly, the assessor’s April 2020 mailing of both a demand for the submission of income and expense information and the form to the plaintiff’s last known address discharged the assessor’s duty to provide the plaintiff with notice of the plaintiff’s obligation to submit the form with the requested income and expense information by the prescribed deadline.

Moreover, mailing the form to a property owner’s last known address satisfied principles of fundamental fairness, as well as the statute’s inherent avail- ability requirements, and it is the burden of the property owner, which is in the best position to know its current address and to notify the municipality of any changes, to ensure that the municipality is apprised of the property owner’s current mailing address.

(One justice concurring in part and dissenting in part)

Argued May 11—officially released August 18, 2026

Procedural History

Appeal from the decision of the defendant’s board of assessment appeals upholding the imposition of a penalty on the plaintiff for failing to timely submit a certain form, brought to the Superior Court in the judicial dis- trict of Stamford-Norwalk and tried to the court, Hon. Kenneth B. Povodator, judge trial referee; judgment for the defendant, from which the plaintiff appealed to the Appellate Court, Moll, Suarez and Prescott, Js., which affirmed the trial court’s judgment, and the plaintiff, on the granting of certification, appealed to this court. Affirmed. James R. Fogarty, with whom was Stephen P. Fogerty, for the appellant (plaintiff). Greenwich Retail, LLC v. Greenwich

Owen T. Weaver, with whom, on the brief, were Jer- emy A. Gustafson and Barbara M. Schellenberg, for the appellee (defendant).

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