Kane, J.
Petitioner commenced this RPTL article 7 proceeding following an unsuccessful challenge to the 2007 tax assessment of a newly constructed single-family residence it owns in the City of Saratoga Springs, Saratoga County. Respondents Assessor, Commissioner of Accounts, Board of Assessment Review and City of Saratoga Springs (hereinafter collectively referred to as respondents) answered, asserting an affirmative defense that the petition was jurisdictionally...
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