Validation of Tax Anticipation Note, Series 2014 v. Humphreys County Board of Supervisors

Summary

The Mississippi Supreme Court considered an appeal from a judgment validating Humphreys County’s $1.2 million tax anticipation note. The court held that the appeal was not moot and concluded that the chancery court had improperly limited consideration of objections concerning the statutory borrowing limit and the sufficiency of petition signatures. The validation judgment was reversed and the case was remanded.

Holdings

1. The Board's motion to supplement the appellate record with documents concerning events occurring after the chancery court's judgment was denied.
2. The appeal was not moot merely because the Board allegedly had repaid the tax anticipation note.
3. The Humphreys County Board of Supervisors did not exceed the statutory borrowing limit in obtaining the $1.2 million tax anticipation note.
4. The chancery court erred by refusing to hear and consider evidence concerning the sufficiency of the signatures on the taxpayer petition.

Questions Presented

1. Whether the Board should be allowed to supplement the appellate record with evidence that the tax anticipation note had been issued and repaid after the chancery court's judgment.
2. Whether repayment of the tax anticipation note rendered the appeal moot.
3. Whether the $1.2 million tax anticipation note exceeded the twenty-five-percent borrowing limit in Mississippi Code Section 19-9-27.
4. Whether the chancery court erred by refusing to consider evidence concerning the sufficiency of signatures on the taxpayer petition.

Disposition

reversed_and_remanded