Randy Mastro's 6,700 is three numbers stacked: more than 2,850 homeowners granted exemptions after handing over personal information, another 2,650 who have filed and are waiting, and 1,210 told outright they are not subject, Mastro among them [7]. That sums to 6,710 [16]. Only two of the three groups are resolved, so the count the city has affirmatively conceded it should not have written to is 4,060, which is 23.9% of the 17,000 letters [17]. Take the headline figure instead and you get 39.4% [15]. Either way it is a high error rate for a mailing the Department of Finance describes to the court as one step in an iterative process [5].
The ratio at the top of the funnel is the more interesting version. Twenty-six thousand candidate properties became 17,000 and then 10,800 [4], which is 15,200 dropped, 58.5% of where the city started [19]; and to arrive at that 10,800 the city put the names, addresses and property values of roughly 950,000 Class 1 and Class 2 owners on its website [3][11]. That is about 88 published households for each one still in the frame [18], or 1.14% of the roll actually in scope [20].
Steven Banks's defence and Mastro's complaint are the same fact read from opposite ends. If nothing is final, nobody is injured, and petitioners who do not owe the tax [12] have no standing [5]. If publication is itself the act, the injury landed in July and cannot be recalled, which is precisely why the relief sought is un-publication and a restart rather than damages [11]. Tax rolls have long been public in New York, though rarely promoted like this [22], and that history is the city's strongest card on the database question.
Sequencing is where the record looks thinnest. Banks told the court the statute required the most recent tax year's data and that 2025 returns would not exist until February 2027 [9], while Mastro says the state handed the city 2025 documents this month and the city used them to narrow the list [10], and asks separately why 2024 returns, available all along, were not used internally first [14]. Someone is wrong about what data existed when, and that answer decides whether burden-shifting was forced or chosen [8].
This is probably wrong, but the exposure sits on the collection method rather than the surcharge: a court that reaches the merits and holds that individualised determinations must precede contact does not repeal the tax, it resets the calendar and hands the Finance Department a year of adjudication work on exemptions it says it never finalised. The counter-thesis is duller and more likely: appellate courts dismiss on ripeness routinely, plaintiffs who owe nothing are the weakest vehicle imaginable, and the city has already had one pause vacated on appeal [6]. What would prove the thesis wrong is a ruling that stops at standing without touching the notice sequence. What nobody in Monday's account priced is the money, since no figure for expected revenue appears in it [21], which means anyone handicapping this is handicapping a procedure.
