Pursuant to Title 3, entitled "Foreclosure of
Tax Lien by Action in Rem," § 1120, Subdivision 2, of the
Real Property Tax Law, the City of Hornell, hereinafter referred to
as the "Tax District," elects to adopt the two-year waiting period
in order to commence the foreclosure by action in rem when, according
to the Tax District, the city owns a tax lien which has been due and
unpaid for a period of at least two years from the date on which the
tax or other legal charges represented thereby became a lien as defined
in the Real Property Tax Law of the State of New York.