Blue Spruce Farms, Inc. v. New York State Tax Commission (64 N.Y.2d 682, 1984)

OPINION OF THE COURT

Order affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (99 AD2d 867).

Concur: Chief Judge Cooke and Judges Jasen, Jones, Wachtler, Meyer, Simons and Kaye.