In Matter of Board of Mgrs. of French Oaks Condominium (23 NY3d at 172-173), the respondent therein moved to dismiss the petition on the basis that the petitioner therein had failed to meet its initial burden of adducing substantial evidence to rebut the presumption that its tax assessment was valid following a two-day hearing which was conducted before a referee, during which the appraiser of the petitioner therein provided testimony, which merely largely tracked his appraisal report.