Mercure, J.
Petitioner is the owner and operator of a residential health care facility that underwent significant physical expansion, the first phase of which occurred from 1997 to 1998. In order to finance that expansion, petitioner borrowed funds via the issuance of tax-exempt bonds by the Dormitory Authority of the State of New York (hereinafter DASNY) (see Public Authorities Law § 1685). Petitioner incurred interim interest expense totalling $881,430...
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