In Sprague Realty Corp. v. Mills, 71 N.Y.S.2d 132 (Sup Ct, NY County 1947) (Schreiber, J.), the court stated that 164 merely authorizes the Tax Commission to "make rules of practice and such rules and regulations to the end that the tax payers may have a hearing." It does not authorize the Tax Commission to modify or enlarge the provisions of Section 163 of the New York City Charter, which provides that the application to correct an assessment "shall be made in writing under oath and shall specify clearly the objection thereto and the grounds for such objection." To interpret Section 164 of the New York City Charter, as urged by the respondents, would enable the Tax Commission to enlarge or modify the legal requirements of an application to correct assessments of real property in the City of New York without proper legislative sanction. In Sprague the owner submitted estimates of income and expenses, and the Tax Commission sought to compel the owner to submit actual income and expense figures. The court found that this went beyond the requirement that the owner "specify clearly the objection to the assessment and the grounds for such objection." Id. In discussing Tax Law 27, the court stated as follows: The right to require an applicant to appear for examination does not authorize the taxing authorities, in lieu of such examination, to write to an applicant who filed a protest, for whatever additional information the assessor requests, and make the furnishing of such information a jurisdictional requirement. No such authority may be read into the section without specific legislative action. Id.