At issue is a mortgage recording tax of $247,911 paid by petitioner in May 1981, in connection with the recording of a construction loan mortgage petitioner obtained from Chase Manhattan Bank (hereinafter Chase) to erect a 16-story office building. In 1980, the State Comptroller, as trustee of the Common Retirement Fund of the New York State Employees' Retirement System (hereinafter the Retirement System), issued a commitment to petitioner...
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