6 E. 112th Street Corp. v. State Tax Commission

There is substantially no dispute as to the facts. Petitioners’ domestic corporations had for a number of years been classified and taxed pursuant to section 182 of the Tax Law which defines a real estate corporation as “ wholly engaged in the purchase and sale of, and holding title to, real estate for itself, or wholly engaged in the business of subleasing real estate * * * or wholly engaged in any of such activities ”. The basis for the change of classification was that the apartment house owned by each petitioner had been altered so that 23.7% of the units represented by one corporation…