Emigrant Bancorp, Inc. v. Commissioner of Taxation & Finance
Appellate Division of the Supreme Court of the State of New York
1Opinion of the Court
OPINION OF THE COURT
Carpinello, J.
The Department of Taxation and Finance issued a notice of deficiency to petitioner for tax years 1998 and 1999. The basis for the deficiency was the Department’s finding, following an audit, that petitioner’s subsidiary, a thrift institution, incorrectly, computed the amount allowable as a deduction for moneys placed in a reserve account for potential losses on qualifying real property loans. While an Administrative Law Judge cancelled the notice of deficiency after a hearing, respondent Tax Appeals Tribunal reversed, prompting this proceeding which involves…
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