James W. Wetzler, as Commissioner of Taxation and Finance of the State of New York, and the New York State Department of Taxation and Finance v. Federal Deposit Insurance Corporation, as Receiver of the Seamen's Bank for Savings, F.S.B., Federal Deposit Insurance Corporation, Counter-Claimant v. James W. Wetzler and New York State Department of Taxation and Finance, Counter-Defendants

38 F.3d 69

James W. WETZLER, as Commissioner of Taxation and Finance of

the State of New York, and the New York State

Department of Taxation and Finance,

Plaintiffs-Appellants,

v.

FEDERAL DEPOSIT INSURANCE CORPORATION, as Receiver of the

Seamen's Bank for Savings, F.S.B., Defendant-Appellee.

FEDERAL DEPOSIT INSURANCE CORPORATION, Counter-Claimant,

v.

James W. WETZLER and New York State Department of Taxation

and Finance, Counter-Defendants.

No. 1273, Docket 93-9068.

United States Court of Appeals,

Second Circuit.

Argued March 30, 1994.

Decided Oct. 13, 1994.

Frederic L. Lieberman, Asst. Atty. Gen. of the…