Supreme Court of Connecticut

FuelCell Energy, Inc. v. Groton

July 24, 2024350 Conn. 1

Summary

The court held that the fuel cell modules and related equipment qualified for the mandatory exemption for class I renewable energy sources, rather than the discretionary cogeneration exemption, because the more specific and later-enacted provision governed. It also upheld the finding that the property remained goods in the process of manufacture on the relevant 2016 assessment date and therefore was exempt for that year. Because the property was exempt, the taxpayers were not required to file personal property declarations, and the resulting penalties were improper.