The issue raised in this CPLR article 78 proceeding is whether the time of receipt or the time of mailing is the pertinent date for the purposes of determining whether a taxpayer, objecting to a determination by the New York City Department of Finance, has made a timely request for a formal hearing? Stated differently, may the city agency claim as a matter of law that, on the one hand, it may obtain the benefit of a mailing date for...
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