(dissenting). I would hold, contrary to the majority, that the petition does not state a cause of action. In holding otherwise, my colleagues in the majority misconstrue section 11-206 of the Administrative Code of the City of New York and call into question the well-established procedure for challenging real property tax assessments in New York City. Accordingly, I respectfully dissent.
As the majority acknowledges, the petitioner was notified of the allegedly erroneous increase in his assessment in plenty of time to challenge it. As the majority also acknowledges, the petitioner did not utilize any of the available procedures to seek a correction in the 2008-2009 classification of its property before that tax year’s assessment became final. As my colleagues also *43acknowledge, the petitioner thus forfeited its right to challenge the assessment in court through an RPTL article 7 tax certiorari proceeding. Finally, the majority acknowledges that the time to commence an article 7 proceeding has, in any event, long passed.
Nonetheless, the majority points out that RPTL article 7 itself recognizes that a tax certiorari proceeding may not be a taxpayer’s only way to challenge a particular tax assessment: “[a] proceeding to review an assessment of real property shall be brought as provided in this article unless otherwise provided by law” (RPTL 700 [1] [emphasis added]; see Corporate Prop. Invs. v Board of Assessors of County of Nassau, 153 AD2d 656, 660 [1989]).1 I agree that, in some situations, an owner of real property in New York City may obtain relief through Administrative Code § 11-206, even without first having challenged the assessment under the New York City Charter and RPTL article 7, but those situations are far more limited than the majority concludes.
Administrative Code § 11-206, which is entitled “Power of the commissioner of finance to correct errors,” provides:
“The commissioner of finance may correct any assessment or tax which is erroneous due to a clerical error or to an error of description contained in the several books of annual record of assessed valuations, or in the assessments-rolls. If the taxes computed on such erroneous assessment have been paid, the commissioner of finance is authorized to refund or credit the difference between the taxes computed on the erroneous and corrected assessments” (emphasis added).
The disposition of this appeal turns on what is meant by the phrase “erroneous due to a clerical error or to an error of description.” As the majority notes, there is no definition of “cleri*44cal error” or “error in description” in the New York City Administrative Code (see e.g. Matter of Astoria Gas Turbine Power, LLC v Tax Commn. of City of NY., 14 AD3d 553, 557-558 [2005], affd 7 NY3d 451 [2006]). Nevertheless, as I discuss below, the text, context, and history of Administrative Code § 11-206, as well as public policy, support only a narrow reading.
In Matter of Hermanee v Ulster County (71 NY 481 [1877]), the Court of Appeals interpreted a statute (L 1869, ch 855, as amended by L 1871, ch 695) that provided for correction of clerical errors in tax assessments by county boards of supervisors. The statute gave county boards of supervisors authority “to correct any manifest, clerical, or other error in any assessments or returns” (71 NY at 485). As to the meaning of “clerical errors,” the Court explained: “ ‘[clerical’ errors are mentioned to distinguish them from, and exclude errors of substance, of judgment, or of law” (id. at 486; see Matter of 9281 Shore Rd. Owners Corp. v Commissioner of Fin. of the City of N.Y., 39 Misc. 3d 768, 770-771 [Sup Ct, Kings County 2013]; cf. Black’s Law Dictionary 659 [10th ed 2014]). Clerical errors are generally limited to arithmetical mistakes such as duplicative entries or calculations (see Matter of Town of Oxford v Chenango County Bd. of Supervisors, 23 AD2d 951, 952 [1965]), or misstatements of the size of a parcel (see Goff v Shultis, 26 NY2d 240, 245-246 [1970]).
The meaning of “an error of description” is similarly narrow. As the majority recognizes, that term “generally refers to circumstances where a given description of real property is so vague or indefinite that it is impossible to ascertain how far the property boundaries extend, where the property is located, and whether the property belongs to the owner” (majority op at 36; see RPTL 502 [2]; 504 [6]; 555; Goff v Shultis, 26 NY2d at 244-245; Blum v Nassau Purch. & Bldg. Corp., 256 NY 232, 234-235 [1931]; McCoun v Pierpont, 232 NY 66, 70 [1921]; Matter of Siemer v Village Bd. of Vil. of Orchard Park, 286 App Div 135, 137-138 [1955]).
Indeed, the New York City Administrative Code expressly states that the purpose of the “description” of a parcel of real property is to enable accurate identification of the parcel for tax purposes: “Assessment-rolls shall be so arranged with respect to number of columns and shall contain such entries as the commissioner of finance shall prescribe, sufficient to identify the property assessed and to show its total assessed valuation” (Administrative Code § 11-217 [emphasis added]; see also Ad*45ministrative Code § 11-203). Thus, an “error of description” in the context of real property taxation has a readily discernable meaning; it refers to errors relating to identification of the property, such as a mistaken lot designation or an error in the metes and bounds description of the subject property.
The history of Administrative Code § 11-206 confirms that that provision should be interpreted narrowly. The provision was introduced into New York City law in 1915 when the legislature added it, in slightly different form, to former section 897 of the Greater New York Charter (see L 1915, ch 592). Before the amendment, former Greater New York Charter § 897 authorized the board of taxes and assessments to remit or reduce taxes on personal or real property if those taxes were found to be excessive or erroneous. As to real property, however, remission or reduction of taxes could be made only within one year after the time to otherwise protest had passed (see L 1915, ch 592). Judge Cardozo wrote that the legislature’s intent in adopting former Greater New York Charter § 897 “was plainly to give relief to taxpayers who have failed for some reason to make their complaints before the grievance day has passed” (People ex rel. Wessell, Nickel & Gross v Craig, 236 NY 100, 105 [1923]). Thus, before amendment, the provision was broad in scope but limited in time.
The 1915 amendment expressly eliminated that one-year limitation for challenges based on clerical errors or errors of description:
“After the expiration of one year from the delivery of the books to the receiver of taxes, the comptroller, with the written approval of the board of taxes and assessments, may correct any erroneous assessment, or tax due to a clerical error, or to an error of description of any parcel of real estate, contained in the annual record of assessed valuations of real estate, and, if the taxes computed on said erroneous assessment have been paid, the comptroller is authorized to refund the difference between the taxes computed on the erroneous and the corrected assessments” (L 1915, ch 592).2
Given that the legislature eliminated the time limit only for cor*46rection of assessments resulting from clerical errors and errors of description, but left in place the one-year time limit for all other errors, it is clear that the legislature did not intend for the amendment to be construed broadly. Otherwise, the legislature would merely have eliminated, for all types of errors, the one-year limit of the original provision (cf. Matter of Hermance v Ulster County, 71 NY at 486). The 1915 Greater New York Charter provision has been amended many times over the past century, including a recodification that moved the provision from the Greater New York Charter to the New York City Administrative Code. But the provision added in 1915, which is now codified as Administrative Code § 11-206, has been largely unchanged in text and has changed not at all in meaning. The right to seek relief is unlimited in time, but the relief available is narrow in scope, as it was always intended to be.
Additionally, public policy considerations support a restrictive interpretation of Administrative Code § 11-206. First, Administrative Code § 11-206 is a statute of “convenience,” affording relief to taxpayers, such as the petitioner, who have neglected to utilize the available procedures to challenge assessments before the assessments become final. Neglect, however, should not be encouraged. As the Court of Appeals reasoned, in giving narrow scope to a similar provision:
“Public policy requires that after taxpayers, those over whom and whose property the assessors have jurisdiction, have been heard, or have had an opportunity to be heard, and have not sought redress in the appropriate form for any supposed error, their mouths should be closed, and the judgment and action of the assessors treated as final. It certainly is against the public interest and policy to permit the taxes collected or paid to be the subject of perpetual litigation, at any time to suit the convenience of the taxpayer, after he has once been heard by the proper tribunal, or has waived the privilege of a hearing by not appearing” (Matter of Hermanee v Ulster County, 71 NY at 488).
In this respect, it should be emphasized that, in addition to the *47petitioner simply ignoring that its property had been reclassified, the petitioner failed to notice that the property’s market value contained on the 2008/2009 Notice of Property Value had increased to $1,497,000 from the 2007/2008 valuation of $153,000. The petitioner does not dispute that it received its “Notice of Property Value” for the 2008/2009 tax year in plenty of time to challenge the assessment, but that it simply failed to do so.
A second and related public policy reason for narrowly interpreting Administrative Code § 11-206 is that a broad reading could cause practical problems. When a taxpayer timely challenges an assessment, the assessing authority is able to inspect the property and determine the merit of the taxpayer’s challenge. The passage of time may compromise that ability (see Matter of Hermanee v Ulster County, 71 NY at 486). Accordingly, Administrative Code § 11-206, which contains no time limit, is ill-suited for the delayed correction of errors that require inspections; “[t]he complainant would have the public at great disadvantage in such a controversy” (id.).
These considerations lead me to conclude that Administrative Code § 11-206 does not apply to the petitioner’s claim of error. The petitioner contends that its property was misclassified and that it should be reclassified. A claim addressed to classification is an error in substance, which must be timely challenged under the provisions of the New York City Charter (see NY City Charter § 163 [c]) and then in an RPTL article 7 proceeding. A claim of misclassification is not a claim of clerical error or misdescription and is not susceptible of correction under Administrative Code § 11-206.
In reaching this conclusion, I recognize that the alleged error in classification might have begun with what may be regarded as a clerical error. But, sometimes, even an error that begins as a clerk’s error becomes an error in substance. For example, in People ex rel. Chamberlain v Forrest (96 NY 544 [1884]), a taxpayer possessed $40,000 in taxable personal property, but, through the inadvertence of the assessors, the value of that property was entered on the tax rolls as $4,000. The assessors recognized the mistake but did not correct it until the taxpayer’s time to challenge it had almost expired; when the correction was made, the taxpayer was not given the required notice, and it failed to challenge the error. The assessors contended that they had merely corrected a clerical error, but the Court of Appeals disagreed: “It was much more than that, for it concerned *48the very substance and extent of the assessment .... The error here, if clerical in its origin, was one which affected the substance of the assessment” (id. at 548-549).3
Here, while I assume for pleading purposes that the alleged misclassification may have occurred because someone in the New York City Department of Finance inadvertently checked the wrong box, rather than because someone there made a mistake in judgment, it simply does not matter how it happened. Regardless, the alleged error is properly considered, for challenge purposes, as a claim that the petitioner’s parcel was misclassified. A claim of an error in classification is not cognizable under Administrative Code § 11-206.
In giving broad meaning to the terms “clerical error” and “error of description,” the majority relies on precedent that is inapposite. After the majority first acknowledges that “error of description” in the context of real property tax assessment relates to limited flaws that affect the proper identification of the property at issue, it then discounts this appropriate limited meaning in favor of a broad definition. The majority states: “[hjowever, this is not the exclusive definition of what constitutes an error of description” (majority op at 37). In support, the majority relies on Matter of Donald E. Axinn Cos. v Board of Assessors of County of Nassau (85 NY2d 838 [1995]), in which a parcel of one acre was, as the Court of Appeals termed it, “erroneously described as four acres” (id. at 839). In my view, Matter of Donald E. Axinn Cos. is irrelevant to the disposition of this appeal. The disputed issue there was whether the acreage error fit within the RPTL 550 (3) (c) definition of an “error in essential fact.” Under that statute, “error in essential fact” includes “an incorrect entry of acreage on the taxable portion of the assessment roll, or the tax roll, or both, which acreage was considered by the assessor in the valuation of the parcel and which resulted in an incorrect assessed valuation” (RPTL 550 [3] [c]). No one disputed that there had been an acreage error; the only question was whether it “was considered by the assessor in the valuation of the parcel and . . . resulted in an incorrect assessed valuation” (id.). The Court held: “The undisputed *49evidence . . . supported the trial court’s conclusion that in this case the acreage error affected calculation of the assessment and the tax owed” (Matter of Donald E. Axinn Cos. v Board of Assessors of County of Nassau, 85 NY2d at 840). In other words, the issue before the Court of Appeals was the sufficiency of the evidence, not the meaning of RPTL 550 (3) (c), and certainly not the legal meaning of the phrase “error of description.”
The majority seizes, however, on the Court’s use, in Matter of Donald E. Axinn Cos., of the phrase “erroneously described as four acres” as an example of how an “error of description” is not limited to identification of the parcel. I disagree that the Court’s colloquial use of the word “described” in that case, in which the legal meaning of “described” or “description” was not at issue, has any relevance to determining the legal meaning of the phrase “error of description” as used in Administrative Code § 11-206.
The majority justifies its broad reading of Administrative Code § 11-206 on two grounds. First, the majority says: “accepting] . . . the respondents’ view that RPTL article 7 is the sole vehicle for challenging a real property tax assessment would render Administrative Code § 11-206 superfluous and meaningless .... Therefore, we reject the respondents’ contention” (majority op at 38). The direct response to this assertion is that the majority has misread the respondents’ contention. The respondents have asserted that RPTL article 7 is the sole judicial remedy for review of a real property tax assessment, not that it was the petitioner’s sole remedy at all. The respondents do not deny that, in appropriate circumstances, a taxpayer may gain relief from a clerical error or error of description under Administrative Code § 11-206. Accordingly, the majority’s assertion that a narrow reading of Administrative Code § 11-206 would render it “superfluous and meaningless” is unfounded.
The majority’s second justification for a broad reading of Administrative Code § 11-206 rests upon its characterization of the petitioner’s failure to timely challenge the assessment under the New York City Charter and RPTL article 7 as a mere “technicality.” In so doing, the majority relies on precedent to the effect that a taxpayer’s challenge to tax assessments should not be defeated by a “technicality.” The precedent on which the majority relies, however, involved technical pleading defects in timely taxpayer challenges to assessments (see Matter of Garth v Board of Assessment Review for Town of Richmond, 13 NY3d *50176 [2009]; Matter of Great E. Mall v Condon, 36 NY2d 544 [1975]). They did not involve taxpayers who had completely failed to challenge their assessments according to the law. Accordingly, that precedent does not support what the majority has done here: widening the narrow path of relief provided by Administrative Code § 11-206 into a broad new avenue of tax assessment review. Simply put, the petitioner’s failure to challenge the classification of its property until years after the taxes were due and payable may not be excused as a mere “technicality.”
If the petitioner is correct that its property was misclassified, it is liable for many times the tax that it should have owed. Were we vested with discretion here, I would likely exercise it to grant relief, despite the petitioner’s failure to timely challenge the assessment before it became final. In, however, interpreting Administrative Code § 11-206 more broadly than was intended, the majority not only gives this petitioner an unauthorized second chance, but also muddles the previously clear procedure for challenging real property tax assessments in New York City.
Ordered that the order and judgment is reversed, on the law, with costs, the respondents’ motion pursuant to CPLR 3211 (a) to dismiss the petition is denied, the petition is reinstated, and the matter is remitted to the Supreme Court, Queens County, for further proceedings consistent herewith, and the respondents’ time to answer the petition is extended until 20 days after service upon it of a copy of this opinion and order (see CPLR 7804 [f]).
Roman and Miller, JJ., concur with Leventhal, J.; Balkin, J.P, dissents in a separate opinion.. For example, a claim that the property is exempt from taxation may be asserted in a CPLR article 78 proceeding (see Hewlett Assoc. v City of New York, 57 NY2d 356, 363-364 [1982]), as may a challenge addressed to the methodology of assessing several properties, rather than the particular assessment of a specific property (see Matter of Woodland Estates, LLC v Soules, 79 AD3d 942, 943 [2010]), and as may a challenge to the removal of a previously granted exemption (see Corporate Prop. Invs. v Board of Assessors of County of Nassau, 153 AD2d at 660-661). Moreover, in municipalities where RPTL article 5 is applicable, an application for the correction of errors may be made under its provisions (see RPTL 550 et seq.; Matter of Level 3 Communications, LLC v DeBellis, 72 AD3d 164, 174 [2010]).
. To be sure, given its punctuation, the 1915 amendment could have been interpreted to authorize a refund after one year of any erroneous assessment or tax, but the courts firmly rejected that interpretation: “To so construe it would be a manifest absurdity in the light of the other sections under this *46title” (People ex rel. Harway Improvement Co. v Berry, 139 Misc. 614, 616 [1931], affd for reasons stated below 233 App Div 851, 852 [1931], affd 258 NY 590 [1932]; see People ex rel. Wessell, Nickel & Gross v Craig, 236 NY 100, 106 [1923]; McKinney’s Cons Laws of NY, Book 1, Statutes § 253 at 417 [punctuation “is subordinate to the text, and is never allowed to control the plain meaning of the act”]).
. The majority seeks to distinguish People ex rel. Chamberlain v Forrest on the ground that the taxing authority there sought to use the asserted “clerical” error as a sword, not a shield. The distinction is unconvincing. The importance of that case is in the Court’s reasoning that what may have begun as a clerical error was properly characterized ultimately as an error in substance.