Connecticut General Statutes

Conn. Gen. Stat. § 12-60 (2026)

Correction of clerical error in assessment

✓ current as of May 2026
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Any clerical omission or mistake in the assessment of taxes may be corrected according to the fact by the assessors or board of assessment appeals, not later than three years following the tax due date relative to which such omission or mistake occurred, and the tax shall be levied and collected according to such corrected assessment. In the event that the issuance of a certificate of correction results in an increase to the assessment list of any person, written notice of such increase shall be sent to such person's last-known address by the assessor or board of assessment appeals within ten days immediately following the date such correction is made. Such notice shall include, with respect to each assessment list corrected, the assessment prior to and after such increase and the reason for such increase. Any person claiming to be aggrieved by the action of the assessor under this section may appeal the doings of the assessor to the board of assessment appeals as otherwise provided in this chapter, provided such appeal shall be extended in time to the next succeeding board of assessment appeals if the meetings of such board for the grand list have passed. Any person intending to so appeal to the board of assessment appeals may indicate that taxes paid by him for any additional assessment added in accordance with this section, during the pendency of such appeal, are paid “under protest” and thereupon such person shall not be liable for any interest on the taxes based upon such additional assessment, provided (1) such person shall have paid not less than seventy-five per cent of the amount of such taxes within the time specified or (2) the board of assessment appeals reduces valuation or removes items of property from the list of such person so that there is no tax liability related to additional assessment.

(1949 Rev., S. 1735; P.A. 90-101, S. 1; P.A. 95-283, S. 35, 68.)

History: P.A. 90-101 added limitation that any clerical omission or mistake may not be corrected later than three years following the tax due date and related provision re increase in notice of the assessment and procedure for appeal to the board of tax review, including payment under protest during pendency of the appeal; P.A. 95-283 replaced board of tax review with board of assessment appeals, effective July 6, 1995.

Limitations on power conferred. 102 C. 210. Clerical omissions or mistakes do not include errors of substance. 136 C. 29. Cited. 179 C. 712; 195 C. 48; Id., 587; 204 C. 336; 240 C. 469; 242 C. 727.

Cited. 33 CA 270. Section does not permit the retroactive adjustment to assessments on basis of late filing penalties. 191 CA 712; judgment affirmed, see 339 C. 157. Common law unjust enrichment claim unavailable to plaintiff whose property was overtaxed for 25 years as claims are time limited under statutory scheme whether excess taxes are paid due to clerical errors, improper property valuations, or “manifestly excessive” assessments. 211 CA 441.

No time limit for making correction. 4 CS 391.

Notes of Decisions
Cited in 15 cases (4 in the last 5 years), 1978–2025 · leading case: Nat'l CSS, Inc. v. City of Stamford, 489 A.2d 1034 (Conn. 1985).
Nat'l CSS, Inc. v. City of Stamford, 489 A.2d 1034 (Conn. 1985). · cites it 44× “*588 On appeal, the plaintiff contends the trial court erred (1) in concluding that its claim for a refund under General Statutes § 12-60 was time-barred by the one year statute of limitations contained in § 12-57, and (2) in failing to find that it was entitled to a refund…”
Stratton v. Drumm, 445 F. Supp. 1305 (D. Conn. 1978). · cites it 13× “In addition to claims made under state law, 2 plaintiffs contend that § 12-60 conflicts with Title VII of the Civil Rights Act of 1964, 42 U.”
Matzul v. Town of Montville, 798 A.2d 1002 (Conn. App. Ct. 2002). · cites it 7× “” The plaintiffs further claim that because § 12-60 does not permit the change as made by the assessor, the court’s ruling cannot stand. We disagree.”
Holbrook v. Casazza, 528 A.2d 774 (Conn. 1987). · cites it 3× “In summary, the defendants accused the plaintiff of: *340 (1) unilaterally changing assessed values in violation of General Statutes § 12-62; 1 (2) making unauthorized substantive changes in the 1981 grand list in violation of General Statutes § 12-60; 2 (3) illegally erasing…”
Konover v. Town of West Hartford, 699 A.2d 158 (Conn. 1997). · cites it 2× “” General Statutes § 12-60 provides in relevant part: “Correction of clerical error in assessment.”
Chamber of Com. of Greater Waterbury, Inc. v. Murphy, 427 A.2d 866 (Conn. 1980). · cites it 2× “Errors may be corrected through the statutory framework, either by the assessor; General Statutes § 12-60; or the tax review process.”
Chapman v. Town of Ellington, 635 A.2d 830 (Conn. App. Ct. 1993). · cites it 4× “Under General Statutes § 12-60, the true and actual value of real property is considered to be the fair market value of the property.”
Albert Bros., Inc. v. City of Waterbury, 485 A.2d 1289 (Conn. 1985). · cites it 2× “2d 161 (1949), where we held that the existence of an express provision, now General Statutes § 12-60, allowing the correction of clerical errors after the time limitation imposed on a tax assessor or board of tax review excluded the possibility that corrections of substance may…”
Tirado v. City of Torrington, 179 A.3d 258 (Conn. App. Ct. 2018). · cites it 4× “On April 26, 2016, the plaintiff filed a motion for summary judgment and a memorandum in support thereof, claiming that the defendant acted without authority when it added the plaintiff's motor vehicle to its 2004 grand list on March 24, 2010, pursuant to General Statutes §…”
Peerless Realty, Inc. v. Stamford, 211 Conn. App. 441 (Conn. App. Ct. 2022). · cites it 33× “The city’s assis- tant corporation counsel responded on November 1, 2017, writing that ‘‘any claim for a refund going back more than three years from the tax due date is time barred under General Statutes § 12-60.’’4 On December 28, 2017, the plaintiff commenced this action by…”
Greenwich Retail, LLC v. Greenwich, 233 Conn. App. 78 (Conn. App. Ct. 2025). “Greenwich valuation of property, assessor or board of assessors ‘‘shall mail a written notice of assessment increase to the last-known address of the owner of the property the valuation of which has increased’’); General Statutes § 12-60 (written notice of increase shall be sent…”
Wilton Campus 1691, LLC v. Wilton (Conn. App. Ct. 2019). · cites it 27× “The assessor’s prac- tice has been to assess, pursuant to General Statutes § 12-60,6 any late filing penalties under § 12-63c (d) ret- roactively, after signing the grand list for a given year.”
Conn. Gen. Stat. § 12-60(a): 1 case
Stratton v. Drumm, 445 F. Supp. 1305 (D. Conn. 1978). “In addition to claims made under state law, 2 plaintiffs contend that § 12-60 conflicts with Title VII of the Civil Rights Act of 1964, 42 U.”
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