New York Supreme Court January 5, 1983 (Aco Realty Corp. v. Srogi)

OPINION OF THE COURT

John R. Tenney, J.

In these assessment review proceedings, petitioners have moved for summary judgment on three different issues: (1) petitioners contend the State equalization rates *410for the years 1972 through 1980 are the proper rates to be applied to the City of Syracuse; (2) section 3-a of the General Municipal Law limiting interest on tax refunds to 3% is