Spain, J.
Petitioner Pyramid Crossgates Company (hereafter PCC) owns a retail shopping mall (hereinafter Crossgates Mall) located in the Town of Guilderland, Albany County. Petitioner Montalba Square Associates, Inc. (hereinafter MSA) formerly owned a single tax lot which is part of the mall property. Pursuant to RPTL article 7, PCC—by notices of petition dated July 29, 1996 and July 10, 1997, respectively—commenced tax certiorari proceedings alleging...
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