Royal Indemnity Co. v. Tax Appeals Tribunal

Proceeding pursuant to CPLR article 78 (initiated in this court pursuant to Tax Law § 2016) to review a determination of *846respondent Tax Appeals Tribunal which sustained a franchise tax assessment imposed under Tax Law article 33.

Petitioner, a property and casualty insurer, is a Delaware corporation licensed to do business in New York and subject to franchise taxation under Tax Law article 33. Petitioner sought to carry forward its 1974 and 1975 net operating losses as deductions on its 1976 and 1977 State franchise tax returns in amounts which exceeded those petitioner deducted on its…