Sheils v. State Tax Commission52 N.Y.2d 954 NY1981Check Treatment OPINION OF THE COURT Order reversed, with costs, and the determinations of the *956State 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.
