Petitioners instituted a proceeding seeking to annul and set aside respondents' denial of certain tax benefits. On this trial, pursuant to CPLR 7804 (subd [h]) the narrow factual issue that this court must decide is the date on which respondents' determination became final and binding on petitioners. (Matter of 301-52 Townhouse Corp. v Click, Supreme Ct, NY County, Aug. 11, 1981, SINCLAIR, J.) If the proceeding was commenced...
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