Appellate Division of the Supreme Court of the State of New York March 5, 1963 (Joseph E. Seagram & Sons, Inc. v. Tax Commission of New York)

lead-opinion

Steuer, J.

The appeal is from an order confirming the assessments for tax purposes for the tax years 1956-57 to 1961-62, inclusive, on the real estate located at 375 Park Avenue. At the outset it is well to bear in mind a fundamental distinction between a proceeding of this character and one to ascertain the value for the purposes of condemnation.