Plaintiff appeals as of right from the trial court’s order granting summary disposition to defendants pursuant to MCR 2.116(C)(10). We affirm.
Plaintiff purchased a tax lien on the subject propеrty at a tax sale on May 5, 1992. At the time of the sale, plaintiff paid the outstanding taxes as well as the past due special assessments against the property, *694 which were included in the purchase price. He was not required to pay the future installments on the existing special assessment at that time. The owner of the prоperty failed to redeem the property and plaintiff took title by tax deed pursuant to MCL 211.70; MSA 7.115 and MCL 211.72; MSA 7.117 on June 17, 1993. The future installments on the special assessment were sеcured by a lien against the property. Plaintiff paid future installments under protest, claiming that all special assessment liens on the property were canceled when he received title to the property and that the lien was illegal.
At the time plaintiff purchased the property, MCL 211.72; MSA 7.117 provided, in pertinent part:
The tax deeds shall convey an absolute title to the land sold, and constitute conclusive evidence of title, in fee, in the grantee, subject, however, to all tаxes assessed and levied on such lands subsequent to the taxes for which the same was bid off.
The statute was amended pursuant to
The tax deeds convey an absolute title to the land sold, and constitute сonclusive evidence of title, in fee, in the grantee, subject, however, to all taxes assessed and levied on the land subsequent to the taxes for which the land was bid off. This title also is subject to unpaid special assessments and unpaid installments of special assessments.
Plaintiff argues that future installments of special assessmеnts are not included in “taxes assessed and levied on [the land] subsequent to the taxes for which the [land] was bid off” under the pre-amendment statute, and, therefore, he wаs entitled to take title to the *695 property free of the unpaid installments of the existing special assessment. We disagree.
This case presents an issue of stаtutory interpretation. The first criterion in determining legislative intent is the specific language of the statute.
House Speaker v State Administrative Bd,
Here, the preamendment statute did not specifically address future installments of existing special assessments, but rather provided for absolute title to pass “subject, however, to all taxes assessed and levied on such lands subsequent to the taxes for which the same was bid off.” Because rеasonable minds could differ with regard to whether unpaid future installments of special assessments are canceled because they were not “assessed аnd levied on [the land] subsequent to the taxes for which the [land] was bid off,” the statute is ambiguous and judicial construction is appropriate. To conduct this inquiry, we must look tо the object of the statute and apply a reasonable construction that best accomplishes its purpose.
Marquis v Hartford Accident & Indemnity (After Remand),
On review de novo, we concludе that plaintiffs interpretation of the statute is insupportable. First, the preamendment statute did not expressly provide
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for cancellation of future installments of special assessments. In this context, where plaintiff is seeking cancellation of an otherwise valid special assessment, we find the rules of statutory construсtion regarding tax exemptions to be helpful. In
Detroit v Detroit Commercial College,
“An intention on the part of the legislature to grant an exemption from the taxing power of the State will never be implied from language which will admit of any other reasonable construction. . . . Exemptions аre never presumed, the burden is on a claimant to establish clearly his right to exemption, and an alleged grant of exemption will be strictly construed and cannot be made out by inference or implication but must be beyond reasonable doubt. In other words, since taxation is the rule, and exemption the exception, the intention to make an exemption ought to be expressed in clear and unambiguous terms; it cannot be taken to have been intended when the language of thе statute on which it depends is doubtful or uncertain; and the burden of establishing it is upon him who claims it.”
Here, the Legislature did not clearly and unambiguously provide for cancеllation of unpaid future special assessments on property sold at a tax sale, and plaintiff has not met his burden of proof that such an inteipretation is reasonable.
Second, contrasted with the language of § 72, we note that the Legislature has expressly and clearly provided for cancellation of unpaid special assessments under another provision of the tax statutes. Where property is bid into the state and not redeemed, absolute title is vested in the stаte. MCL 211.67; MSA 7.112. When this occurs, all taxes and
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special assessments that are charged against or are liens on the property at the time title becomes absolute in the state are canceled,
1
the property is removed from the tax rolls, and the state and its inferior taxing units must bear the loss. MCL 211.67a(2); MSA 7.112(1)(2);
Wayne Co Chief Executive v Mayor of Detroit,
Third, we find that the Legislature intended, as a general rule, for property owners whо benefit from an improvement paid for by a special assessment to incur the financial burden of that assessment. See
Carmichael v Village of Beverly Hills,
Finally, contrary to plaintiffs argument, we find that the 1993 amendment of § 72 did not effect a substantive change in the law that was applied retroactively to plaintiffs detriment. This finding is supported by the House Legislative Analysis and Senate Fiscal Agency Bill Analysis of
Given the foregoing, we hold that plaintiff was not entitled to have the future installments of the special assessment on the subject property canceled pursuant to MCL 211.72; MSA 7.117. Accordingly, summary disposition was properly granted to defendant.
Notes
Certain special assessments axe not actually canceled, but axe defexxed. If the piopexty is latex sold by the state, these special assessments axe due and payable as part of the pinchase price of the piopexty. MCL 211.67a(3); MSA 7.112(1)(3). If the Lеgislature intended that these assessments would ultimately be paid by the puichasei of the property from the state, there is no reason to believe that it intended to relieve the purchaser at the tax sale of this burden.