Norwich bulletin., 1914-11-28
CORPORATION BONDS NOT
 EXEMPT FROM TAXATION
Issued by Connecticut Gas, Electric
 Light and Manufacturing ces'

Tax Commissioner William H. Cor Din has received from Attorney Gen eral John H. Light an opinion upon his inquiry as to whether bonds issued 3y tae electric light. gas and manu- facturlng corporations of this state may be exempt from taxation under Section 2319 of the General Statutes.
 In his answer he says that Section 2S23 of the General Statutes express ly makes such bonds taxable except when otherwise provided.
 The law Is clear that exemption strued
 He further finds that the only stat ute which can be claimed to exempt in any way such property from tax ation is Section 2319 of the Gen eral Statutes which proyides:
 Money issued on interest with an agreement that the borrower shall pay the taxes thereon, and secured by a mortgage on real estate in this state, shall, to an amount equal to the as- .sessed value of the mortgaged land in the assessment list of the town where 1t is situated, be exempt from taxa ton; but the excess of any such loan over such valuation shall be assessed and taxed in the town where the lend CT resides in the same manner as other money on interest"
 It will be noticed that the express sion used in this section is merely money loaned on interest" while in Section 2323. which imposes taxes, the words used are notes. bonds, stocks, moneys" etc. Tn view of the express designations of Section 2323. the omis- sion of the words notes, bonds and stocks in Section 2319, which in its present form was passed at a later date, Is very significant.
 If further assistance is needed to in- dicate the legislative intent. such as- ststance is found in the fact that inn posing taxes upon moneys at interest, the expression was used twice, once in reference to moneys at interest secured by notes or bands or responsible per- sons and a second time in reference to moneys on interest secured by mort gage of real estate.
 "An moneys at interest secured by notes or bonds of responsible persons, resident in this state or elsewhere ex- eept money loaned by this state, and all moneys on interest, secured by mortgage on real estate in this state or elsewhere, more than the owners pay interest for, shall be set in the list at per cent"
 Thus, at this early date, there seems to have been a differentiation. made by the legislature between moneys at in- terest secured by bonds, and rnoenys on interest secured, by mortgage" When, therefore. the act in question tOeCLlOn 1019D OInltS all TeEer611CS to moneys at interest secured by bonds, " the natural inference is that the leg islature did not intend that section to apply to anything other than the or dinary nor Ftgage loans.
 Considered alone this intent seems therefore to be conclusively shown. A fortiori is such the case when consid- cred in connection with the rule o4 construction against exemptions above referred to.
 It is, true that the policy o2 this state is to a.yaid double taxation. but nevertheless, tax will not be declared void because 1t may impose double taxation, for the reason that the con- stitution does not forbid such taxa tion.
 Nettleton's Appeal, 76 Conn, 235 Security Co. v5. Hartford. 61 Conn. 1o2; Lockwood vs. Weston, 61 Conn 21s.
 It may be that where bonds are se- cured by tRuEt mortgage deeds they