Peters, C. J.
In this tax appeal, the only issue is whether it is proper to revalue and reassess real property once a subdivision of the property has been approved and recorded, even though the conditions attached to the subdivision approval have not yet been fulfilled. The plaintiffs, Richard and Joyce Pauker (taxpayers), filed an amended complaint pursuant to General Statutes § 12-119,1 alleging that the defendants, [337]*337Linda Roig, the tax assessor of the town of Weston, and the town of Weston had grossly overvalued the taxpayers’ property. Both parties moved for summary judgment. The trial court denied the motion of the taxpayers and granted the motion of the defendants for summary judgment. The taxpayers appealed from the judgment of the trial court to the Appellate Court, and we transferred the appeal to this court pursuant to Practice Book § 4023 and General Statutes § 51-199 (c). We affirm the judgment of the trial court.
The facts are undisputed. The taxpayers, as trustees, owned three contiguous parcels of land in Weston that consist of approximately eighty-two acres. On July 22,1991, the Weston planning and zoning commission approved the taxpayers’ application for a subdivision of the three parcels into twenty-nine lots, with roads and dedicated open space. The subdivision approval allowed the taxpayers to proceed with development in two phases, a first phase comprising seven lots, and a second phase comprising the remaining twenty-two lots. Construction of phase I began promptly. Under the terms of the subdivision approval, however, before [338]*338construction could begin on phase II, the taxpayers were required to comply with specified conditions including engineering studies and plans for dealing with drainage concerns. Despite the costs and delays associated with the required performance of these conditions, the taxpayers did not appeal the validity of the subdivision approval. On August 29, 1991, the taxpayers recorded subdivision maps on the Weston land records for the entire subdivision project.
After the recordation of the subdivision maps, the tax assessor prepared new field cards for the 1991 grand list for each of the lots in the approved subdivision. Written notice of the assessments was sent to the taxpayers. The taxpayers appealed only the assessments on lots eight through twenty-nine (phase II) of the subdivision. The board of tax review reduced the assessment on these lots from $4,009,760 to $3,007,320. The present record does not disclose whether the taxpayers took an appeal from the decision of the board of tax review.2
Instead, the taxpayers initiated a plenary action, pursuant to § 12-119, in which they claimed that their tax assessments are so manifestly excessive as to be illegal. They maintained that the defendants had exceeded their authority by undertaking an interim revaluation of the taxpayers’ property simply because the subdivision approval had been granted and recorded. In the view of the taxpayers, until they have actually fulfilled the conditions incorporated in the subdivision approval, their property should not be revalued and reassessed. The trial court disagreed with the taxpayers’ contention in light of the provisions of General Statutes § 12-42,3 which requires separate assessments of sep[339]*339arate lots, and General Statutes § 12-55,4 which authorizes reassessments “required by law.”
In their appeal, the taxpayers renew their argument that the conditional approval of their subdivision application does not justify an immediate revaluation and reassessment of their property as individual building lots because, until the conditions are satisfied, the property cannot be further developed and the lots cannot be sold. We agree with the trial court that this argument is unpersuasive.
The principles that govern a complaint filed pursuant to § 12-119 are not in dispute. In contrast to § 12-117a,5 [340]*340which allows a taxpayer to challenge the assessor’s valuation of his property, § 12-119 allows a taxpayer “to bring a claim that the tax was imposed by a town that had no authority to tax the subject property, or that the assessment was ‘manifestly excessive and could not have been arrived at except by disregarding [341]*341the provisions of the statutes for determining the valuation of [the real] property . . . .’ (Emphasis added.) Our case law makes clear that a claim that an assessment is ‘excessive’ is not enough to support an action under this statute. Instead, § 12-119 requires an allegation that something more than mere valuation is at issue.” Second Stone Ridge Cooperative Corp. v. Bridgeport, 220 Conn. 335, 339-40, 597 A.2d 326 (1991); accord Connecticut Light & Power Co. v. Oxford, 101 Conn. 383, 392, 126 A. 1 (1924).
To fit their claim for relief within § 12-119, the taxpayers have advanced three arguments. They maintain that the reassessment of their property was illegal because: (1) the conditional subdivision approval conferred no immediate benefit upon their property and a reassessment on that basis was manifestly excessive; (2) reassessment of their property violated General Statutes (Rev. to 1991) § 12-62, which expressly provides for ten year revaluations of real property and has been judicially construed to preclude interim revaluations and reassessments; and (3) the onerous nature of the conditions attached to the subdivision approval, and their nonfulfillment at the time of the revaluation, distinguish this case from Fyber Properties Killingworth Ltd. Partnership v. Shanoff 228 Conn. 476, 636 A.2d 834 (1994) (Fyber Properties), in which conditional subdivision approval was held to authorize revaluation and reassessment.
The taxpayers’ first claim warrants little discussion. As a matter of fact, they have advanced no evidence in support of their contention that subdivision approval, per se, confers no benefit that enhances the value of their property. It is too late to raise a factual question now, when all the parties agreed at trial that there were no factual disputes in this case. As a matter of law, they cannot raise such a claim under § 12-119, which requires a showing that an assessment is both mani[342]*342festly excessive and illegal. Disagreements about the measurement of a benefit to real property do not make an assessment illegal.
The taxpayers’ second claim rests on a series of cases in which this court has construed General Statutes §§ 12-626 and 12-64 7 to manifest the intent of the legislature that the “true and actual valuation” of real property that is required by § 12-64 is ordinarily accomplished by the ten year revaluation that is required by § 12-62. The taxpayers cite several cases in which we held, accordingly, that assessors need not undertake an interim revaluation on the ground of market fluctuations, at least in the absence of a showing of the destruction or expansion of the property, a substantial change in its use or zoning classification, or a decision by the taxpayer to go out of business. Ralston Purina Co. v. Board of Tax Review, 203 Conn.
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Peters, C. J.
In this tax appeal, the only issue is whether it is proper to revalue and reassess real property once a subdivision of the property has been approved and recorded, even though the conditions attached to the subdivision approval have not yet been fulfilled. The plaintiffs, Richard and Joyce Pauker (taxpayers), filed an amended complaint pursuant to General Statutes § 12-119,1 alleging that the defendants, [337]*337Linda Roig, the tax assessor of the town of Weston, and the town of Weston had grossly overvalued the taxpayers’ property. Both parties moved for summary judgment. The trial court denied the motion of the taxpayers and granted the motion of the defendants for summary judgment. The taxpayers appealed from the judgment of the trial court to the Appellate Court, and we transferred the appeal to this court pursuant to Practice Book § 4023 and General Statutes § 51-199 (c). We affirm the judgment of the trial court.
The facts are undisputed. The taxpayers, as trustees, owned three contiguous parcels of land in Weston that consist of approximately eighty-two acres. On July 22,1991, the Weston planning and zoning commission approved the taxpayers’ application for a subdivision of the three parcels into twenty-nine lots, with roads and dedicated open space. The subdivision approval allowed the taxpayers to proceed with development in two phases, a first phase comprising seven lots, and a second phase comprising the remaining twenty-two lots. Construction of phase I began promptly. Under the terms of the subdivision approval, however, before [338]*338construction could begin on phase II, the taxpayers were required to comply with specified conditions including engineering studies and plans for dealing with drainage concerns. Despite the costs and delays associated with the required performance of these conditions, the taxpayers did not appeal the validity of the subdivision approval. On August 29, 1991, the taxpayers recorded subdivision maps on the Weston land records for the entire subdivision project.
After the recordation of the subdivision maps, the tax assessor prepared new field cards for the 1991 grand list for each of the lots in the approved subdivision. Written notice of the assessments was sent to the taxpayers. The taxpayers appealed only the assessments on lots eight through twenty-nine (phase II) of the subdivision. The board of tax review reduced the assessment on these lots from $4,009,760 to $3,007,320. The present record does not disclose whether the taxpayers took an appeal from the decision of the board of tax review.2
Instead, the taxpayers initiated a plenary action, pursuant to § 12-119, in which they claimed that their tax assessments are so manifestly excessive as to be illegal. They maintained that the defendants had exceeded their authority by undertaking an interim revaluation of the taxpayers’ property simply because the subdivision approval had been granted and recorded. In the view of the taxpayers, until they have actually fulfilled the conditions incorporated in the subdivision approval, their property should not be revalued and reassessed. The trial court disagreed with the taxpayers’ contention in light of the provisions of General Statutes § 12-42,3 which requires separate assessments of sep[339]*339arate lots, and General Statutes § 12-55,4 which authorizes reassessments “required by law.”
In their appeal, the taxpayers renew their argument that the conditional approval of their subdivision application does not justify an immediate revaluation and reassessment of their property as individual building lots because, until the conditions are satisfied, the property cannot be further developed and the lots cannot be sold. We agree with the trial court that this argument is unpersuasive.
The principles that govern a complaint filed pursuant to § 12-119 are not in dispute. In contrast to § 12-117a,5 [340]*340which allows a taxpayer to challenge the assessor’s valuation of his property, § 12-119 allows a taxpayer “to bring a claim that the tax was imposed by a town that had no authority to tax the subject property, or that the assessment was ‘manifestly excessive and could not have been arrived at except by disregarding [341]*341the provisions of the statutes for determining the valuation of [the real] property . . . .’ (Emphasis added.) Our case law makes clear that a claim that an assessment is ‘excessive’ is not enough to support an action under this statute. Instead, § 12-119 requires an allegation that something more than mere valuation is at issue.” Second Stone Ridge Cooperative Corp. v. Bridgeport, 220 Conn. 335, 339-40, 597 A.2d 326 (1991); accord Connecticut Light & Power Co. v. Oxford, 101 Conn. 383, 392, 126 A. 1 (1924).
To fit their claim for relief within § 12-119, the taxpayers have advanced three arguments. They maintain that the reassessment of their property was illegal because: (1) the conditional subdivision approval conferred no immediate benefit upon their property and a reassessment on that basis was manifestly excessive; (2) reassessment of their property violated General Statutes (Rev. to 1991) § 12-62, which expressly provides for ten year revaluations of real property and has been judicially construed to preclude interim revaluations and reassessments; and (3) the onerous nature of the conditions attached to the subdivision approval, and their nonfulfillment at the time of the revaluation, distinguish this case from Fyber Properties Killingworth Ltd. Partnership v. Shanoff 228 Conn. 476, 636 A.2d 834 (1994) (Fyber Properties), in which conditional subdivision approval was held to authorize revaluation and reassessment.
The taxpayers’ first claim warrants little discussion. As a matter of fact, they have advanced no evidence in support of their contention that subdivision approval, per se, confers no benefit that enhances the value of their property. It is too late to raise a factual question now, when all the parties agreed at trial that there were no factual disputes in this case. As a matter of law, they cannot raise such a claim under § 12-119, which requires a showing that an assessment is both mani[342]*342festly excessive and illegal. Disagreements about the measurement of a benefit to real property do not make an assessment illegal.
The taxpayers’ second claim rests on a series of cases in which this court has construed General Statutes §§ 12-626 and 12-64 7 to manifest the intent of the legislature that the “true and actual valuation” of real property that is required by § 12-64 is ordinarily accomplished by the ten year revaluation that is required by § 12-62. The taxpayers cite several cases in which we held, accordingly, that assessors need not undertake an interim revaluation on the ground of market fluctuations, at least in the absence of a showing of the destruction or expansion of the property, a substantial change in its use or zoning classification, or a decision by the taxpayer to go out of business. Ralston Purina Co. v. Board of Tax Review, 203 Conn. 425, 435-39, 525 A.2d 91 (1987); Uniroyal, Inc. v. Board of Tax Review, 182 Conn. 619, 629, 438 A.2d 782 (1981) (Uniroyal II). The taxpayers in,this case maintain that these precedents demonstrate that the revaluation and reassessment of their property violated § 12-64.
The taxpayers’ reliance on the case law under § 12-64 is flawed, however, in a number of important respects. The taxpayers assume that a subdivision approval is [343]*343not so substantial a change in the property’s use or zoning classification as would warrant an interim revaluation under Ralston Purina Co. and Uniroyal II. They assume further that these cases limit the power of assessors to undertake an interim revaluation. They assume finally that the authority exercised by the defendants in this case was an interim revaluation rather than an original valuation of building lots that had no prior existence. These assumptions are of doubtful validity.
We need not decide today whether subdivision approvals fall within the exceptional circumstances hypothetically identified in Ralston Purina Co. and Uniroyal II, because those cases provide little guidance for the issue before us. Ralston Purina Co. and Uniroyal II held only that tax assessors ordinarily are not statutorily required under § 12-64 to undertake interim revaluations. These cases did not address the extent to which tax assessors might invoke other statutes in support of the authority to undertake an interim revaluation, should they decide to do so. We recognized this distinction between mandated and permissive revaluations in 84 Century Ltd. Partnership v. Board of Tax Review, 207 Conn. 250, 251, 260-62, 541 A.2d 478 (1988), in which we concluded that, although tax assessors cannot be required to make an interim revaluation of property, they may do so in accordance with § 12-55, which authorizes assessors to equalize the tax lists.
Our decision in 84 Century Ltd. Partnership furnishes a persuasive analogy for this case, in which the defendants based their revaluation of the taxpayers’ property on §§ 12-42 and 12-55. We have construed § 12-42 to require tax assessors to make “a separate description of, and valuation for, each parcel of real estate.” Empire Estates, Inc. v. Stamford, 147 Conn. 262, 265, 159 A.2d 812 (1960); State v. Erickson, 104 Conn. 542, [344]*344547, 133 A. 683 (1926). Once the taxpayers’ subdivision map for twenty-nine lots had been fled on the town records, the tax assessor could no longer tax their property on the basis of three larger parcels of land that had ceased to have any legal existence.8 “If assessors fail to list real estate in separate parcels, they may be compelled to do so by mandamus.” Empire Estates, Inc. v. Stamford, supra, 265. These cases furnish considerable support for the defendants’ contention that the tax assessments in this case should be viewed as having arisen out of an original valuation rather than a revaluation of the taxpayers’ property. Whether §§ 12-42 and 12-55 require original assessments or authorize reassessments has, however, no special significance for present purposes. However characterized, the statutes clearly establish the legality of the tax assessor’s exercise of her authority in this case.
The taxpayers’ final argument is that their case falls within the exception contemplated by Fyber Properties, supra, 228 Conn. 483, in which we recently held that, as a general rule, subdivision approval, rather than recording of a subdivision map, furnishes an appropriate occasion for the revaluation and reassessment of real property. In Fyber Properties, we relied on our analysis of the applicable real property statutes to conclude that “[t]he legislature has . . . indicated that, in the subdivision of property, the focal point is the date of approval.” Id. We declined to decide, however, “the date upon which a property becomes taxable as a subdivision if the approval has been appealed, or if conditions imposed upon an approval have not been fully satisfied before the assessment date.” Id., 481.
In light of the considerations adduced in Fyber Properties and the authorities cited earlier in this opin[345]*345ion, we now conclude that we can discern a bright-line rule underlying our taxing and real property statutes with regard to subdivision approvals. Absent an appeal challenging its validity, the approval of a subdivision authorizes a tax assessor to tax the property as subdivided lots rather than as the undifferentiated parcel or parcels that preceded the approval. The authority to tax subdivided lots in such a manner means that taxpayers have no basis for challenging such a revaluation under § 12-119. To the extent that conditional approvals deprive taxpayers of immediate economic returns from their investment, such conditional approvals raise issues only of valuation, which properly may be addressed only by appeals under § 12-117a.
The judgment is affirmed.
In this opinion the other justices concurred.