The parties have stipulated that the 1958 assessment on the property was erroneous and should be reduced by a substantial amount and Special Term has so ordered. It is also stipulated, however, that appellants did not file a written protest as required by then section 27 of the Tax Law (now Real Property Tax Law, § 512) against the 1959 assessment or commence a proceeding in conformance with section 290-a of the Tax Law (now Real Property Tax Law, § 702) within...
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