OPINION OF THE COURT
SPAIN, J.
Petitioner commenced a proceeding pursuant to RPTL article 7 challenging the assessed value of industrial property it owns in the Town of Bethlehem, Albany County, for the 1996-1997 tax year. A final order in that proceeding was entered upon the parties' stipulation to reduce the assessed value of the subject property from $24.1 million to $17.5 million.
In 1998, respondent Town of Bethlehem conducted a Town-wide revaluation...
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