In a petition brought to challenge the denial of a refund claim, a New York State Administrative Law Judge held that the New York State “mansion tax” was properly owed by the purchaser of residential real property from the United States Government, which had acquired the property in an asset foreclosure sale relating to a federal tax lien. Matter of 182-188 Columbus Avenue LLC, DTA No. 823746 (N.Y.S. Div. of Tax App., Mar. 14, 2013). The purchaser claimed that its purchase from the government was exempt from the tax as a “conveyance given in connection with a tax sale.” The ALJ, interpreting the phrase “tax sale” based on its ordinary meaning, found that all tax liens had already been discharged when the purchaser acquired the property, and held that the $8.3 million purchase from the U.S. Government did not qualify for exemption.