In 1967, petitioner-respondent Ronald Associates No. 2 converted a building it owns in Manhattan from single-room occupancy to a multiple dwelling, thus qualifying for and receiving an exemption in the amount of $200,000 for a 12-year period under section J51-2.5 of the Administrative Code of the City of New York, implementing the enabling legislation, section 489 of the Real Property Tax Law. In 1980, respondent obtained a final judgment in a tax certiorari proceeding directing...
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