Sheils v. State Tax Commission (52 N.Y.2d 954, 1981)

OPINION OF THE COURT

Order reversed, with costs, and the determinations of the State Tax Commission reinstated (see Matter of Gurney v Tully, 51 NY2d 818).

Concur: Chief Judge Cooke and Judges Jasen, Gabrielli, Jones, Wachtler, Fuchsberg and Meyer.