Crew III, J.
These two proceedings pursuant to RPTL article 7 seek to challenge the tax assessment imposed upon approximately 250 acres of real property formerly occupied by IBM Corporation and located in the Town of Ulster, Ulster County. In early 1994, IBM elected to vacate the facility and placed the property on the real estate market. Following a failed attempt by the State to purchase a portion of the property in 1996, the property was subdivided into 27 separate...
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