case which deals with the proper interpretation of a number of interrelated statutes which are all intended secret with me to annoy taxpayers and writers from protest assessments from the two thousand and nine tax year the real property in rockland county even discussing the section ten thirty one ten thirty one as a temporary developer's exemption which was an accident august of two thousand and three vishal repeats developers as a result of the depressed economy in two thousand and nine and eleven without reference to assessments without reference to anything other than it is to be immediately affected as of the date it was enacted and therefore it applies as of the that's that's part of the reason that's why we're here today is because this is the original developer couldn't obtain financing so as a result as a result been active restructuring in refinancing which resulted in the transactions are ultimately an issue sale was for use the city uses occupancy for the use of developments as a commercial residential property then in that instance the developers because that would be would be scripts that's quite clear according in fact an initial sale for the purposes of ten thirteen and therefore the developers exemption would still apply and this is the submission is in fact supported by the bom carriageways which again we have cited in our  in rockland county there simply aren't that many comparable sales of lots in bulk for the purposes of holding them for developments that's exist perhaps exist in other counties this is why the board of reviews your honour's in an acting section temp thirty and ten thirty one general assembly was trying to balance a policy of protecting developers encouraging development on the one hand against the need of counties and school districts for tax revenue on the other section ten thirty one was explicitly a temporary fix and acted in response to the recession the purpose was to incursion developers jumping during the difficult time by adding that extra incentive to get the ball rolling temporarily removing the initial sale as a condition that would try many of her rental treatment and that would encourage other developers and maybe to pick up the ball and carry the ball if that first cladding developer ran into difficulties and needed to sell was a way to just encourage these taxpayers had the benefit of the developers perforate to treatment in two thousand and eight and that is because the original owner into the sea adventures recorded their plight in two thousand and seven and t january first and they don't change just because happy change hands these players have the benefit of that a tax rate for most of two thousand and eight different story in two thousand and nine it's unlikely they'd be heard of her  it both ways you can't argue for something that you like one year and something that you don't like then asked these these taxpayers are essentially asking this court to disregard the plain language of both sections and giving the court really no throughout this case the plaintiffs it argued that they are in the class that section ten thirty was crafted to protect where the dream of the mormons in the statute is a matter of legislative parotid the general assembly knows how to purchases already some divided by the land legislature sense they wouldn't put that term initial sense in the statute as it self evident that property can change hands and number of times before the development is finished  about that change the assessment we don't we don't go back in and fix the assessment for the tax year it was already exist in january first so in effect it anybody who bought property already planted from august of of two thousand and eleven and that as i said it's a policy of trying to not only christoffel a person get in and start the ball rolling but for other developers to to better buy that property if the first developer runs into difficulties i property development is not certain game even in the best of times you know property can change hands this was just a little bit of extra protection in fact it specifically for that difficult economic period case that was the case where the county in the middle of the tax year tried to change the taxpayer's assessment and the property tax appeal board and ultimately the public court said no you can't do that your property taxes are fixes in january first you can't go back and back date somebodies assessment there really is nothing that you do that only now the company a property act really has no relation to the statutes that are an issue in this case the company property i just found in a completely separate section of i can i can look up the page states for the court the court's probably already familiar with it so i don't remember the exact dates of the sales certainly peter had made an adjustment in his consideration because first of all when the plaintiff when the plaintiffs argued that look some of these are not really arm's length transactions because they are the properties that our clients purchased he tapped with those have consideration and then it made adjustments downward for the fact that  conditions if the group wishes i could  as this court has explained in kankakee county the armstrong case the property tax appeal board's role in evaluating evidence and credibility is unique a mere difference of opinion as to value is not sufficient for rehearsal and here the final administrative decision value was well supported by the it's not record because ph have had not only the board of reviews like testimony by mr wilson it had that spreadsheet of comparable sales and that that is a nice check on the record i got that right in my statement of facts and i miss cited it is nine fifteen in you know in the argument because there is handwriting date stamp and i looked at it quickly it's at nine eleven to the record and the the value so that tells us that the board of review was pretty much on target in its estimation of value and with this sort of evidence before it really cannot be said that the p temps findings to fair market value were against the manifest weight of the evidence you know sometimes me but i believe that statute stated that it is applicable to assessments after a after the specific dates that that's my memory of what the statute stated now immediately means immediately it means right now today and as of this tax year knots down the road between ten on with regards to that you process arguments ah i don't think we phrased it as the court cannot look at the records and instead you turn in what's it's you know determine what is trek and what is not correct peter have it has its own opinions the supreme court has its own opinions but this court is the ultimate