United States Steel Corp. v. Gerosa

Breitel, J. P.

The seeks to annul the determination of the Comptroller of the City of New York under which all its receipts from certain lump sum contracts were assessed, without allocation, under the New York City General Business and Financial Tax Law (General City Law, § 24-a et seq.; Administrative Code of City of New York, § B46-1.0 et seq.; § B.B41-1.0 et seq.). The tax is imposed upon the privilege of doing business within the city. The taxpayer argues that an assessment of its receipts from the lump sum contracts without allocation is invalid, because “ the major part of the work done…