Tax Redemption Amount – “Preservation Improvements” Defined

Ex parte J.C. King, III, [Ms. SC-2022-0653, May 19, 2023] __ So. 3d __ (Ala. 2023). On certiorari review, the Court unanimously (Stewart, J.; Parker, C.J., and Shaw, Wise, Bryan, Sellers, Mendheim, Mitchell, and Cook, JJ., concur) affirms the Court of Civil Appeals construction of the term “preservation improvements” in § 40-10-122(c), Ala. Code 1975, of the tax redemption statute. The Court holds “[c]onsistent with the purpose of the 2002 amendment of reducing residential blight, the legislature required redemptioners of property containing a residential structure to pay the value of ‘preservation improvements,’ a term it defined by adopting language that this Court has previously interpreted to mean ‘valuable and useful additions and improvements to the property,’ Rodgers [v. Dixon], 239 Ala. [72,] 74, 193 So. [741,] 743 [(1940)], including improvements beyond those necessary to merely prevent further deterioration.” Ms. *15.

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