Unum Real Estate Corp. v. Graves

For many years the petitioner had been a corporation “ wholly engaged in the purchase and sale of, and holding title to, real estate for itself,” as defined by section 182 of the Tax Law. It continued that character until November 22, 1930, when it purchased a large quantity of the stock of the City Investing Company, which it still holds, for business purposes.

On May 24, 1938, the State Tax Commission finally determined that the petitioner pay a franchise tax of $5,922.03 for the calendar year 1931, pursuant to the provisions of section 182 of the Tax Law, *418“ based on business for the…