People ex rel. Erie Railroad v. State Tax Commission

It appears that notice of a hearing on these assessments was given relator by the Commission pursuant to sections 37 and 45-a of the Tax Law, but no appearance, protest or written *143complaint specifying its objections were made by the relator before the Tax Commission in the manner required by the statute.

“ An assessment of a special franchise by the tax commission may be reviewed in the manner prescribed by article 13 of this chapter, and that article applies so far as practicable to such assessment, in the same manner and with the same force and effect .•as if the assessment had been made by…