Petitioner sought to have franchise fee payments, made to the City of New York for use of property pursuant to section 626 of the Real Property Tax Law, set off against its special franchise tax obligation. Under an agreement which expired October 31, 1980, the provisions of section 626 were waived. In pertinent part, this consent agreement, adopted and approved in 1972 to be retroactively effective from November 1, 1970, provided that all such payments pursuant to this agreement...
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