Babbin v. State Tax Commission

Mikoll, J. (dissenting). I respectfully dissent. Petitioner was born and raised in New York State. He was a long-time employee of the Pennwalt Corporation, a multinational company with operations both within and without the United States. Petitioner worked for Pennwalt for a number of years in South America and then at the Pennwalt division in Rochester. In tbe latter part of 1972 he accepted an appointment as general manager of Pennwalt’s European headquarters with the intent of expanding the company’s European business. Pennwalt’s existing European facilities were located in Ireland.…