OPINION OF THE COURT
GEORGE B. CERESIA, JR., J.
The petitioners have commenced the above-captioned proceedings pursuant to article 7, title 2 of the Real Property Tax Law to seek review of special franchise assessments established by the State Board of Real Property Services (hereinafter, the State Board). Five of the proceedings have been commenced by the owners of the special franchise, either Time Warner Entertainment Company, L.P. or TWI Cable, Inc....
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