Norwich bulletin., 1922-12-01
NATIONAL BANKS NOT EXEMPT
 FOR TAXES ON REAL ESTATE

National banks in Connecticut are not entitled to any exemption for taxes paid on real estate, according to an opinion just handed down by Attorney General Frank E. Healey. His interpretation of the law was gwen on request of Tax Commissioner William H. Blodgett who sought ruling with respect to the as sessment of the tax on deposits in say ings department of national banks
 Under Chapter 233 of the Public Acts of 1921, nation banks are entitled t the same exemption as savings banks except that the exemption of the amount invested in tax exempt securities shall be only such proportion thereof as the de- posits in the bank. The act also pro- vides, however, that the amount of taxes paid on real estate shall not be exempt
 ed under the provisions of this act if the same is claimed as an exemption un-
 der section 1901 of the statutes. The situation was caused by one bank, the name of which IS not given in rendering it's report. It claimed de-
 auctions of s4S,777.15, but also claimed a further deduction of $12,777.15. The claim was made by the bank that if the amount of tax paid on real estate is in excess of the amount which the bank | would be required to pay under one of | these statutes, then the excess could be i deducted under the provisions of the other statute mentioned The tax com
 missioner held, however, that if the
 claim were allowed and a deduction per
 nitted by authority of both statutes, the ! bank would pay no tax whatever, to
 the state under tieher statute, and there
 still would be deductible balance.
 Double Exemption Sought | The attorney general says:
 l Any interpretation that this bank is entitled to this double exemption
 would in effect be a repeal of part oi chapter 23S. I can find no such inten' tion of repeal under existing law. IT fact I am unable to see any confiic in the language of Chapter 209 and 23;
 of 1921.
 "A rule of construction of general ap ! plication that our courts have adopted and always followed in construing stat utes make it my duty to give effect tt : both of these statutes if they can be con sistently read together.
 i "As the general assembly is presumed to know the effect If it's legislation, it I not reasonable to presume that within the brief period of eleven days it en acted legislation that would be conflict ing in it's terms.
 "The reason for the enactment of thi particular provision of chapter 24o of tn session of 1921 was to prevent thes great commercial banking institution : which are run for a profit from havin an unfair advantage by way of taxa ton over savings banks by the erectio : of buildings that are largely devoted t commercial purposes and are source C |. revenue to said bank.
 : 'fI cannot conceive how the lntsntio Q of the legislature could be only bette 5 expressed than in the language used i this statute. It Is an absolute prof,ib tion against allowing any national ban Ito deduct the amount of taxes paid Q T it's real estate of the same has bee 2 claimed as to exemption under the othe 2 statute.
 'I beg to advise you that this bank t not entitled to any exemption for tax, d paid by 1t on It's real estate under u -I provisions Of Chapter 2SS of the sessic g laws of 1s2l.'