Capitol Cablevision Systems, Inc. v. State Tax Commission

OPINION OF THE COURT

Yesawich, Jr., J.

Since its creation in 1966, petitioner, a cable television program supplier in the Albany area, has filed corporate tax returns as a business corporation under article 9-A of the Tax Law. On September 6, 1978, as a result of a routinely conducted audit of randomly selected returns, the Corporation Tax Bureau of the State Department of *101Taxation and Finance informed petitioner that it had reclassified petitioner, for corporation franchise tax purposes, from a general business corporation to a transportation and transmission corporation and that petitioner…