Spain, J.
Petitioner, a non-for-profit health service corporation licensed in New York, commenced this CPLR article 78 proceeding seeking refunds of real property taxes paid on a parcel of property which it owns in the Town of Liberty, Sullivan County. Pursuant to RPTL 556, petitioner filed applications with the Sullivan County Real Property Tax Service Agency for refunds of the taxes which it paid in 1998, 1999 and 2000, claiming that the property is wholly exempt...
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