The issue presented on this appeal is whether the instant CPLR article 78 proceeding instituted on November 18, 1983, more than four months after the determination of the State Tax Commission sought to be reviewed became final, is time barred by the provisions of CPLR 217. We conclude that this proceeding was not timely commenced. The order of Special Term should therefore be reversed and the petition dismissed.
On November 12, 1981, respondent State Department of...
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