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Is an invalid Certificate of Occupancy an "irregularity in a vital matter" to re-open a PAR?

Posted by No Time Limit on November 12, 2001 at 07:43:59:

3 years after LL was granted a PAR reversing a Rent Overcharge Order & Finding, it turns out building CO in records of DOB only allowed 377 residential units whereas rents were being charged and collected on 428 units during whole time of DHCR's review process.
After this longstanding abuse of multiple dwelling laws, can the LL now attempt to evade being subject to penalties by trying "to legalize existing conditions" - and is this "cure" retroactive?

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