Spain, J.
Pursuant to RPTL article 7, petitioner City of Troy commenced proceedings to reduce its 1996, 1997 and 1998 real property tax assessments on approximately 2,800 acres of property located in the Town of Pittstown, Rensselaer County. The property, known as the Tomhannock Reservoir, is petitioner's major water source, as well as a source of revenue derived from water sales to other municipalities, and is comprised of five separately designated tax parcels....
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