Piccolo v. New York State Tax Appeals Tribunal

OPINION OF THE COURT

McCarthy, J.

Petitioners were members of Piccolo Properties, LLC, which was certified pursuant to General Municipal Law article 18-B as a Qualified Empire Zone Enterprise (hereinafter QEZE). The *109corporation owned five parcels of property in the Auburn Empire Zone. The Auburn Empire Zone is located within the Downtown Auburn Business Improvement District, which levies a charge — known as the downtown improvement tax — on all properties in the district to pay for things such as beautification projects, cultural events, business promotion, safety programs and accessibility…