In New Jersey Transit Corp. v. Borough of Somerville, 139 N.J. 582, 661 A.2d 778 (1995) New Jersey Transit sought to contest the local real property tax assessments levied against its real property by the Borough of Somerville after the expiration of the April 1 deadline for filing tax appeals. 139 N.J. at 584, 661 A.2d 778. The Court held that the ten-year limitations period granted in N.J.S.A. 2A:14-1.2 must yield to the specific period granted in N.J.S.A. 54:3-21. Id. at 591, 661 A.2d 778. The Court stated: "The Legislature, in enacting N.J.S.A. 2A:14-1.2, was concerned only with establishing a uniform ten-year statute of limitations for actions commenced by governmental entities where no such limitation had previously existed under the doctrine of nullum tempus . . . ." Id. at 587, 661 A.2d 778. The Court determined that the "Legislature could not have intended N.J.S.A. 2A:14-1.2 to give governmental entities a longer statute of limitations then they previously had enjoyed." Id. at 588, 661 A.2d 778.