Lockport Union-Sun & Journal, Inc. v. Preisch

Goldman, J. (dissenting).

The prevailing opinion quite correctly asserts that this ease turns upon the construction of section 12 of the Tax Law, but I am unable to agree with the result reached. In my view the majority opinion fails to take due heed of well-recognized canons of statutory construction. It is arguable whether the statute is ambiguous. The pivotal words are 1 ‘ tabulated statements ’ ’ and it is with the definition of these words that I cannot concur. I am not unmindful of Judge Leabned Hand’s wise admonition that one should not make “ a fortress out of the dictionary” (Cabell…