In our opinion, having adopted title 3 of article VII-A of the Tax Law of the State of New York, respondent was required to foreclose, by action in rem, as provided in said title 3, the lien of all taxes which it owned, and which were due and unpaid for a period of at least four years from the date when the taxes and assessments represented thereby became a lien. Its right to proceed under its charter provisions, however, by sale and foreclosure of tax liens less than four...
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