OPINION
KELLEHER, Justice.
On December 31, 1978, Northgate Associates (Northgate) owned an apartment complex, located in the town of Middletown, that had an assessed value of $1,169,050. Sometime after the advent of 1979 the municipality embarked on a general reevaluation of all its ratable property. As a consequence, on December 31, 1979, Northgate's complex had an assessed value of $4,284,850. When Northgate received notice of this assessment, it filed...
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