Respondent's motion to dismiss the petition in this proceeding under article 7 of the Real Property Tax Law involves an issue of first impression in this State as to the taxability of modular homes used for display purposes only. Section 102 (subd. 12, par. [b]) of the Real Property Tax Law defines "real property" to mean and include: "Buildings and other articles and structures, substructures and superstructures erected upon...
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