Ordered that the judgment is affirmed, with costs.
The plaintiff, Regional Economic Community Action Program, Inc. (hereinafter RECAP), is a charitable corporation located in the City of Middletown. In 2004, after the City, the entity responsible for listing certain RECAP properties as fully taxable on the tax assessment rolls used by both the City and the defendant, Enlarged City School District of Middletown (hereinafter the District), denied RECAP's applications...
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