New York State Department of Taxation and Finance
Office of Counsel
Advisory Opinion Unit
The Department of Taxation and Finance received a Petition for Advisory Opinion from the [name redacted] (Petitioner). Petitioner asks whether it is subject to mortgage recording taxes imposed by Article 11 of the Law on a construction
loan it procured from name of [bank redacted] (Bank) which is secured by a mortgage. We conclude that the recording of such a mortgage by Petitioner is not exempt from mortgage recording taxes.
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