OPINION
WILLIAM H. GINDIN, Chief Judge.
PROCEDURAL BACKGROUND
This matter comes before the court as an adversary proceeding brought by debtor and debtor-in-possession, Custom Distribution Services, Inc. ("CDS") against the City of Perth Amboy, Tax Assessor ("the City"), to determine, modify, and reduce the real property taxes assessed by the City, pursuant to 11 U.S.C. § 505(a).
CDS contends that the City's valuations of real...
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