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  5. 34 N.Y.2d 440 (1974)
 

GUTH REALTY v. GINGOLD

34 N.Y.2d 440 (1974)

Ed Guth Realty, Inc., Appellant-Respondent, v. Benjamin M. Gingold, as Commissioner of Assessment of the City of Syracuse, Respondent-Appellant. (And Six Other Proceedings.) Ed Guth Realty, Inc., Respondent, v. Benjamin M. Gingold, as Commissioner of Assessment of the City of Syracuse, Appellant. (And Six Other Proceedings.)

Court of Appeals of the State of New York.

Decided June 26, 1974.

Attorney(s) appearing for the Case

Edward P. Kearse, Corporation Counsel (Thomas J. Lowery, Jr. of counsel), for respondent-appellant in the first above-entitled proceedings and for appellant in the second above-entitled proceedings.

Franklin J. Schwarzer for appellant-respondent in the first above-entitled proceedings.

Franklin J. Schwarzer for respondent in the second above-entitled proceedings.

Louis J. Lefkowitz, Attorney-General (Ruth Kessler Toch, Carl Rosenbloom and Joseph P. McCale of counsel), amicus curiae.

Joseph Jaspan, County Attorney (Leon Friedman of counsel), for County of Nassau, amicus curiae.

Adolph Koeppel, William Siegal and Bernard Sommer for 860 Executive Towers, Inc. and others, amici curiae.

Chief Judge BREITEL and Judges JASEN, JONES, WACHTLER, RABIN and STEVENS concur.

GABRIELLI, J.

The primary question raised by these cross appeals in these so-called inequality proceedings brought under article 7 of the Real Property Tax Law concerns the kind of proof which can properly form the basis for determination of the ratio of assessed value to fair market value as provided under subdivision 3 of section 720 of the Real Property Tax Law. The years in question are 1964 through 1970...

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