In 1985 petitioner, along with ETA Realty Corporation, of which she is the sole stockholder and officer, executed two in rem installment agreements in connection with mortgage financing received for two parcels of real property located at 22 and 27 East 127th Street in Manhattan. As a result of defaults on these agreements, the City of New York acquired title to the parcels in April, 1987.
ETA filed applications for the release of the lots within four months...
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