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AC § 11-1312
In cases where the taxpayer has applied for a refund and has instituted proceedings under article seventy-eight of the civil practice law and rules to review a determination adverse to the taxpayer on his or her application for refund or has deposited the amount of tax assessed in connection with proceedings under section 11-1310 of this chapter, the comptroller shall set up appropriate reserves to meet any decision adverse to the city.
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