Benacquista, Polsinelli & Serafini Management Corp. v. Commissioner of Taxation & Finance

OPINION OF THE COURT

Yesawich Jr., J.

Petitioner owned two large parcels of real property in the City of Albany, referred to as the Karner Road property, developed as an industrial park, and the Washington Avenue Extension property, which was developed as an office park. Subdivision plans were filed for the two properties in 1978 and 1982, respectively. Petitioner sold several lots from each property prior to the effective date of the real property transfer gains tax law on March 28, 1983. Between that date and November 21, 1986, 12 more parcels were sold from the Karner Road property, and four…