RAC Corp. v. Gallman

This is a proceeding under article 78 of the CPLR (transferred to the Appellate Division of the Supreme Court in the Third Judicial Department by order of the Supreme Court at Special Term entered in Albany County) to review a determination of the State Tax Commission holding petitioner liable for sales taxes in the amount of $50,043.92 including interest.

Since incorporation in 1939 until 1964, Republic Aviation Corporation was engaged in the performance of prime contracts with various agencies of the United States Government. During World War II and for many years prior to 1965, Republic was…