Petitioner owns several parcels of land in Madison County and commenced proceedings pursuant to article 7 of the Real Property Tax Law to review the tax assessments upon 13 of these parcels for the years 1975 and 1976. It was alleged in the petitions that the 13 parcels were tax exempt under subdivision 1 of section 421 of the Real Property Tax Law due to the fact that petitioner was an educational institution and the parcels were used exclusively for educational purposes...
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