Argued January 13, 1981;
decided February 12, 1981
*945APPEARANCES OF COUNSEL
Bruce K. Carpenter for appellant.
Philip A. Erickson for respondent.
Robert Abrams, Attorney-General (Stanley Fishman and Shirley Adelson Siegel of counsel), pro se.
OPINION OF THE COURT
Order affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (72 AD2d 950; see, also, Real Property Tax Law, ยง 504, subd 4).
Concur: Chief Judge Cooke and Judges Jasen, Gabrielli, Jones, Wachtler, Fuchsberg and Meyer.
52 N.Y.2d 943
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