Town of Rye v. New York State Board of Real Property Services

OPINION OF THE COURT

Memorandum.

The order of the Appellate Division should be affirmed, with costs.

The Town of Rye and a Town of Rye taxpayer commenced this CPLR article 78 proceeding to challenge the State Board of Real Property Services’ decision not to establish a segment-special equalization rate for the City of Rye. Judicial review of *795state equalization rates is governed by section 1218 of the Real Property Tax Law, which provides that an action may be commenced “in the appellate division of the supreme court in the manner provided by [article 78] upon application of the county; city,…