Mercure, J.
Petitioners are the owners of a 137-unit apartment complex (hereinafter the Project) located in the Town and Village of Potsdam, St. Lawrence County. The Project is subsidized by the United States Department of Housing and Urban Development (hereinafter HUD) pursuant to a 30-year Housing Assistance Payments Contract and a Regulatory Agreement executed in 1978 and 1979, respectively. Under the terms of those agreements, HUD established "contract rents"...
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