The rollout of the tax, passed by the state but administered by the city, has been a source of intense controversy and backlash from homeowners across New York. The lawsuit takes issue with the city’s publishing of a property tax roll with nearly 1 million properties—some of which, the Department of Finance noted, could be subject to the tax. A number of property owners complained, however, they were full-time city residents and should not have been flagged for the new tax. “The result is an impermissible burden shift of determining primary residence onto New York City residents with respect to a tax they don’t owe and should never have been bothered with in the first place,” Mastro wrote. Those with non-owner-occupied homes valued at $5 million or more and co-ops valued at $1 million or more are subject to the tax.