STEIN, J.
Petitioners own approximately 108 acres of land in the Town of Esopus, Ulster County, which includes ponds, streams, 2,200 feet of Hudson River frontage and scenic views of the river. In 1978, the Department of Environmental Conservation (hereinafter DEC) certified 104 acres of the land as a tract of privately owned forest land eligible for a tax exemption pursuant to RPTL 480-a.
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