This is an article 78 proceeding pursuant to which the petitioner seeks to set aside a determination by the respondent Tax Commission of the City of New York denying to the petitioner a tax exemption (Real Property Tax Law, § 421) on certain property owned by it in the Borough of Manhattan.
The statute (Real Property Tax Law, § 421, subd. 1, par. [a]) exempts from taxation "real property owned by a corporation or...
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