Metromedia, Inc. v. Tax Commission

*108OPINION OF THE COURT

Alexander, J.

We hold on this appeal that the advertising display frames erected by petitioner-respondent, Metromedia, Inc., on the elevated structures of the New York City Transit Authority are real property within the meaning of section 102 (subd 12, par [b]) of the Real Property Tax Law and are properly subject to taxation as such pursuant to section 300 of the Real Property Tax Law.

The facts here are not in dispute. Metromedia, through its subsidiary Foster-Kleiser, erects, leases and maintains outdoor advertising displays on property owned by the New York City Transit…