Egan Jr., J.
Petitioner Angelo Balbo is the sole shareholder of Angelo Balbo Realty Corp. (hereinafter Balbo Realty) and the sole member of Angelo Balbo Management, LLC (hereinafter Balbo Management), a real estate management company, which is certified as a qualified empire zone enterprise (hereinafter QEZE) (see Tax Law § 15 [a]; General...
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