In Matter of New York Tel. Co. v. Nassau County, 267 AD2d 629, lv denied 95 NY2d 756) the Appellate Division determined that ORPS advised claimant of the change in the law and thereafter reminded claimant on at least two occasions of such change (id. at 631). The Appellate Division further held that claimant miscalculated the ABPs attributable to the utilities and, as a result, the utilities' "tax shares increased dramatically and excessive taxes were levied upon them" (id. at 632).