Legal Opinion

British Land (Maryland), Inc. v. Tax Appeals Tribunal

Appellate Division of the Supreme Court of the State of New York

Decided March 24, 1994PublishedCited by 1 opinion

1Opinion of the Court

Mikoll, J. P.

Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law § 2016) to review a determination of respondent Tax Appeals Tribunal which sustained franchise tax assessments imposed under Tax Law articles 9-A and 27.

Petitioner was incorporated in Delaware in May 1973 and maintains its principal place of business in London, England. Petitioner is an indirect subsidiary of British Land Company Pic., an international real estate investment company headquartered in London. One of the latter’s primary business purposes was to purchase strategically located, prime…

2Cases cited13 opinions

  1. Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
  2. Hans Rees' Sons, Inc. v. North Carolina Ex Rel. MaxwellSupreme Court of the United States · 1931
  3. Butler Bros. v. McColgan, Franchise Tax CommissionerSupreme Court of the United States · 1942
  4. Exxon Corp. v. Department of Revenue of Wis.Supreme Court of the United States · 1980
  5. Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992

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3Cited by1 opinion

  1. British Land (Maryland), Inc. v. Tax Appeals TribunalNew York Court of Appeals · 1995

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