Spain, J.
In July 2003, petitioner commenced this proceeding/action seeking to nullify the taxation imposed upon its real property by the Bethlehem Water District. Respondents moved for summary judgment. Supreme Court granted the motion on the grounds that the proceeding/action was time-barred and that petitioner had failed to post an undertaking before commencing it as mandated by statute. Petitioner appeals, and we now affirm.
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