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E OF NEW YORK COMMISSIONER OF TAXATION AND FINANCE ADVISORY OPINION PETITION NO. M940404A On April 4, 1994, a Petition for Advisory Opinion was received from The Society of the New York Hospital, 525 East 68th Street, New York, New York 10021. The issue raised by Petitioner, The Society of the New York Hospital, is whether the transfer of real property from Petitioner to Royal Charter Properties - Westchester, Inc. (hereinafter "RCPW") and the subsequent leaseback of the real property from RCP.
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