In Lewis v. Schwartz, 119 A.D.2d 116, 506 N.Y.S.2d 32, the Appellate Division, First Judicial Department addressed this issue and stated, in relevant part, that: "If this Court were to affirm Special Term's decision, it would have to adopt a reading of 203-a(7) of the Tax Law indefinitely extending a dissolved corporation's time to seek release of foreclosed property for as long as the possibility of corporate revivification exists, a theoretically limitless period. Thus, if fifty years after dissolution a corporation were to pay its franchise tax it would, to paraphrase Special Term, still have the right (that it had at the time of dissolution) to redeem the property by paying the back taxes. Presumably, during the 50 years or whatever period intervened between dissolution and reinstatement, the City would be obliged to retain the property or at the very least any funds received from its condemnation (see Admin. Code D17-25.0(f)) so as not to impair the dissolved corporation's apparently undying "equity" in its late asset. Indeed, Special Term's construction of Tax Law 203-a(7) so as to toll the running of the redemption period indefinitely is not only impracticable, forcing the City, at least in theory, to retain properties or funds derived from their condemnation in perpetuity, it also works a gross inequity. The rule espoused by Special Term in fact creates a strong incentive to a corporation with property subject to in rem foreclosure to forfeit its charter so as to preserve its "equity" in the property for as long as it takes to finance release. Clearly, this was not the result intended by the Legislature when it enacted 203-a(7) of the Tax Law. That provision is better understood as an inducement to prompt payment of franchise taxes so that those rights restored to the corporation can be exercised before the time for doing so lapses" (Lewis v. Schwartz, 119 A.D.2d 116, 120, 506 N.Y.S.2d 32, 35, [1st Dept., 1986]).