Norwich bulletin., 1922-12-22
NO TAX EXEMPTION
 FOR NATIONAL RANKS


 National banks in Connecticut are not entitled to any exemption for taxes paid on real estate, according to an opinion handed down by Attorney Gen erai Frank E. Healy. His interpreta- tion of the law was given on request ot Tax Commissioner William H. Blodgett who sought g. ruling with respect to the assessment of the tax on deposits in savings departments Of national banks.
 Under Chapter 23S Of the Public Acts of 1921, national banks are entitled to the same exemption as savings banks except that the exemption of the amount invested in tax exempt securi- ties shall be only such proportion there of as the deposits in the bank. The act also provides, however, that the amount of taxes paid on real estate shall not be exempted under the pro- vision Of this act if the same is claim ed as an exemption under section 1901 Of the statutes.
 The situation was caused by or. bank, tk1 S:Eie of which is not given in rendering its report It claimed de- auctions of $4S,777.15, but also claim ed a further deduction of $I2,777.15. The claim was made by the bank that if the amount of tax paid on real es- tate is in excess of the amount which the bank would be required to pay un- der one of these statutes, then the ex- cess could be deducted under the pro- visions of the other statute mentioned, The tax commissioner held, however, that if the claim were allowed and a deduction permitted by authority of both statutes. the bank would pay ID tax whatever, to the state under either statute, and there still would be a de- dpctible balance.
 The attorney general says:
 Any interpretation that this bank ia entitled to this double exemption would in effect be a repeal of part Of chapter 2SS. I can find no such inten- tion of~ repeal under existing law In fact I am unable to see any conflict in the language of Chapters 2O9 and 233 of 1921.
 "A rule Of construction of general application that our courts have adopt ed and always followed in construing statutes, make it my duty to giEe effect to both of these statutes if they can be consistently read together
 "As the general assembly is pre- sumed to know the effect of its legis- lation, it is not reasonable to presume that within the brief period of eleven days it enacted legislation that would be conflicting in its terms.
 '"The reason for the enactment cf this particular provision of Chapter 24O of the session of 1921 was to pre- vent these great comm ercial banking institutions which are run for a profit from having an unfair advantage by way of taxation over savings banks by the erection of buildings that are large ly devoted to commercial purposes aid are a source of revenue to said bank.
 T cannot conceive how the intention of the legislature could be any better Oppressed than in the language used in this statute. It is an absolute prohib:- tion against allowing any national bank to deduct the amount of taxes paid on its real estate if the same has been claimed as an exemption under the other statute.
 ''IV beg to advise you that this bank is not entitled to any exemption for taxes paid by it on it's real estate un- der the provisions of Chapter 23s of the session laws of 1921"