Leonard J. Accardo, Petitioners v. Gregory S. Brown

Summary

The court held that taxpayers holding perpetually renewable leaseholds on government-owned land were the equitable owners of both the land and improvements for ad valorem taxation purposes. Because equitable ownership made the taxpayers the owners for taxation purposes, the statutory provision directing certain governmental leasehold interests to be taxed only as intangible personal property did not apply. The court answered the certified question affirmatively and approved the decision below.