Ordered that the judgment is affirmed, with costs.
The petitioner is a tax-exempt corporation which owns 12 pieces of property (hereinafter the properties) in the City of Middletown. In 2004 the petitioner applied to the respondent Bonnie Bernaski, as Commissioner of Assessment of the City of Middletown (hereinafter the Commissioner), for exemption of the properties from taxation pursuant to RPTL 420-a. The Commissioner denied the applications. The petitioner then...
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