LILLEHAUG, Justice.
Hennepin County (the County) assessed real estate taxes on two properties in Medina (the Subject Properties) owned by STRIB IV, LLC (STRIB IV). STRIB IV submitted an application to the County to classify the Subject Properties under Minnesota's Green Acres statute, Minn. Stat. § 273.111 (2014). The County denied that application. The tax court affirmed the County's decision. Because we conclude the tax court correctly determined that STRIB IV is not entitled to Green Acres classification, we affirm.
The facts of this case are undisputed. STRIB IV is a single-member limited liability company (LLC) of which Richard T. Burke is the only member. Burke uses STRIB IV solely as a landholding entity to shield himself from personal liability. STRIB IV has owned the Subject Properties (which total 39.96 acres) in fee simple since November 2007. STRIB IV leases eight acres to an unspecified entity to produce hay, and two acres grow noncommercial apples. Burke does not live on the Subject Properties.
Burke personally owns eight parcels adjoining the Subject Properties, and owns a ninth adjoining parcel through another single-member LLC, Richard T. Burke II, LLC. Those nine parcels include 230 acres used for agriculture, and have Green Acres classification.
STRIB IV applied to the County seeking Green Acres classification for the Subject Properties. The County denied the application,
STRIB IV argues that the tax court erred when it concluded, as a matter of law, that land owned by a single-member LLC such as STRIB IV is not eligible for Green Acres classification. We review de novo whether the tax court committed an error of law, such as an erroneous interpretation of a statute. ILHC of Eagan, LLC v. Cty. of Dakota, 693 N.W.2d 412, 418-19 (Minn.2005).
The Green Acres statute "provides property tax relief to land that is primarily devoted to agricultural use `and located on the fringes or amidst expanding urban areas.'" Raisanen v. Cty. of Hennepin, 678 N.W.2d 669, 670 n. 1 (Minn.2004) (quoting Barron v. Hennepin Cty., 488 N.W.2d 290, 291 (Minn.1992)). Property classified under the Green Acres statute is valued "solely with reference to its appropriate agricultural classification," rather than according to its market value. Minn.Stat. § 273.111, subd. 4(a).
The statute specifies, in relevant part, what land qualifies for Green Acres tax classification:
Id., subd. 3(b). An "authorized farm entity," in turn, includes family farms, family farm corporations, family farm trusts, authorized farm corporations, authorized livestock farm corporations, family farm partnerships, authorized farm partnerships, family farm LLCs, and authorized farm LLCs. See Minn.Stat. § 500.24, subd. 3(a) (2014) (citing Minn.Stat. § 500.24, subds. 2(b)-(f) and (j)-(m) (2014)).
Because STRIB IV does not argue that it is a family farm LLC or authorized farm LLC, the issue here is whether the phrase "owned by individuals" encompasses parcels owned by single-member LLCs such as STRIB IV. Minn.Stat. § 273.111, subd. 3(b). The goal of statutory interpretation is to effectuate the intent of the Legislature. Minn.Stat. § 645.16 (2014); Brayton v. Pawlenty, 781 N.W.2d 357, 363 (Minn.2010). We begin our analysis "by determining whether the plain language of the statute clearly and unambiguously requires a particular result in this case." Marks v. Comm'r of Revenue, 875 N.W.2d 321, 325 (Minn.2016). "When the words of a law in their application to an existing situation are clear and free from all ambiguity," we must give effect to the plain meaning of the law. Minn.Stat. § 645.16; accord Am. Tower L.P. v. City of Grant, 636 N.W.2d 309, 312 (Minn.2001). A statute is ambiguous only if, as applied to the facts of the case, it is susceptible to more than one reasonable interpretation. Staab v. Diocese of St. Cloud, 813 N.W.2d 68, 72-73 (Minn.2012).
"In construing the meaning and scope of a statute, the words of the statute govern and are given their common and approved usage." Chapman v. Comm'r of Revenue, 651 N.W.2d 825, 831 (Minn.2002). According to the weight of dictionary authority, the most common usage of "individual" is to mean a single natural person. See, e.g., New Oxford American Dictionary 885 (2010) ("[A] single human being as distinct from a group, class, or family.");
We conclude that the Green Acres statute adopted the common usage of the word "individual" to mean a natural person. We must interpret each section of a statute in light of the surrounding sections. Am. Family Ins. Grp. v. Schroedl, 616 N.W.2d 273, 277 (Minn.2000). Here, the sections immediately surrounding subdivision 3(b) of the Green Acres statute use the word "individual" in the context of a natural person. Under subdivision 3a(c), real estate may continue to qualify for Green Acres classification if it is "transferred from a family farm [LLC] upon its termination to a son or daughter of an individual who had an ownership interest in the company." Minn.Stat. § 273.111, subd. 3a(c) (emphasis added). We doubt that, in referring to the sons and daughters of individuals, the Legislature was referring to subsidiaries of corporate entities. Similarly, under subdivision 3(a)(3), real estate qualifies for Green Acres classification if it "is the homestead of an individual who is part of an entity described in paragraph (b), clause (1), (2), or (3)." Id., subd. 3(a)(3) (emphasis added). These uses of "individual" — and the fact that the statute distinguishes individuals from entities — only make sense as references to natural persons.
Thus, a plain reading of the Green Acres statute offers only one reasonable interpretation: "individuals" are natural persons. STRIB IV is not a natural person.
STRIB IV next argues that the statute's silence with respect to single-member LLCs such as STRIB IV creates an ambiguity,
"[S]ilence in a statute regarding a particular topic does not render the statute unclear or ambiguous unless the statute is susceptible of more than one reasonable interpretation." Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753, 760 (Minn. 2010). Ambiguity through statutory silence is rare; we have identified it only twice. MBNA Am. Bank, N.A. v. Comm'r of Revenue, 694 N.W.2d 778 (Minn.2005);
Here, the Green Acres statute is not completely silent on the issue of which persons or entities are entitled to have their properties receive the Green Acres classification. It specifically identifies eligible properties, including those owned by certain LLCs,
Next, STRIB IV argues that the court can use the Green Acres statute's "broadly construed" directive to extend Green Acres classification to properties owned by single-member LLCs. Minn.Stat. § 273.111, subd. 12. A broad construction cannot be employed to enlarge a statute's reach in the face of unambiguous language, however. See Billion v. Comm'r of Revenue, 827 N.W.2d 773, 778 (Minn.2013); Krueger v. Zeman Constr. Co., 781 N.W.2d 858, 863-64 (Minn.2010).
In Krueger, a case strikingly similar to this one, we declined to add to an unambiguous statute's language, despite the statute's directive that it be construed broadly. The individual plaintiff and her single-member LLC sued under the Minnesota Human Rights Act, which penalizes sex discrimination in the "performance of the contract." Minn.Stat. § 363A.17 (2014). But only the single-member LLC was a party to the contract. Krueger, 781 N.W.2d at 860. Despite the statute's directive that it be "construed liberally," Minn.Stat. § 363A.04 (2014), we affirmed the dismissal of the individual plaintiff's claim, distinguishing between the natural person and the legal entity. 781 N.W.2d at 862-64. We reasoned that, because the unambiguous statute offered a cause of action only to the LLC, we could not "add provisions to the statute," 781 N.W.2d at 864, despite the statute's "remedial nature," id. at 863 (citation omitted).
Likewise, the Green Acres statute, as applied here, is unambiguous. It limits eligibility for Green Acres classification to real estate owned by "individuals" (natural persons) and a specified list of legal entities that does not include single-member LLCs such as STRIB IV. Minn.Stat. § 273.111, subd. 3(b). Thus, we cannot accept STRIB IV's invitation to apply the "broadly construed" directive to adopt an unreasonable interpretation that would add to the statute's list of eligible classes.
STRIB IV next argues that, because single-member LLCs are generally disregarded for tax purposes, the Legislature did not need to list them in the Green Acres statute. The County responds that the Legislature and the Minnesota Department of Revenue have narrowly specified, and thus limited, when single-member LLCs are disregarded, and that neither did so in relation to the Green Acres statute. We agree.
When the Legislature wants a statute to disregard single-member LLCs as separate entities, it specifically says so. For example, section 272.02, regarding exempt property, states that "property owned or operated by a limited liability company consisting of a sole member shall be treated as if owned or operated by that member." Minn.Stat. § 272.02, subd. 35 (2014). That subdivision specifically limits itself, however, to "the exemptions granted by subdivisions 1 to 33." Id. The Green Acres statute is not within that list of exemptions.
For federal income tax purposes, a non-corporate business entity "with a single owner can elect to be ... disregarded as an entity separate from its owner." 26 C.F.R. § 301.7701-3(a) (2016). The Minnesota income tax statute follows the federal law, but only as to chapters 289A and 290. See Minn.Stat. § 290.01, subd. 3b (2014). The Green Acres statute is not in either chapter.
In sum, the Legislature has explicitly stated when a taxing authority may disregard a single-member LLC. There is no such statement in or referring to the Green Acres statute. We decline to do what the Legislature has not done.
Finally, STRIB IV argues that not disregarding a single-member LLC produces an absurd result. We presume that the Legislature did not intend an absurd result. Minn.Stat. § 645.17(1) (2014). We interpret a statute according to its purpose rather than its plain meaning only in the "exceedingly rare case in which the plain meaning of the statute `utterly confounds' the clear legislative purpose of the statute." Schatz v. Interfaith Care Ctr., 811 N.W.2d 643, 651 (Minn.2012) (quoting Weston v. McWilliams & Assocs., Inc., 716 N.W.2d 634, 639 (Minn.2006)); see Wegener v. Comm'r of Revenue, 505 N.W.2d 612, 617 (Minn.1993). We have had only one such case: Wegener v. Comm'r of Revenue, 505 N.W.2d at 617.
STRIB IV's absurdity argument fails. Burke has chosen not to live on or primarily farm the Subject Properties. Moreover, he has opted to reduce his exposure to personal liability by holding certain parcels, including the Subject Properties, in corporate form. Although Burke's personal and business choices mean that the Subject Properties will not receive Green Acres classification, the purpose of the statute is not "utterly confounded." The result required by the Green Acres statute's plain language is not absurd.
Affirmed.