American Can Co. v. State Tax Commission

The petitioner appeals from an order of the Supreme Court which dismissed the petition in a proceeding-under article 78 of the Civil Practice Act to review and annul a determination of the State Tax Commission which denied, as barred by the time limitations imposed by subdivision 1 of section 214 of the Tax Law, petitioner’s application for revision of franchise taxes assessed under article 9-A of the Tax Law for the privilege years ended October 31, 1953 and 1954; petitioner contending- that the taxes were computed upon an erroneous method of allocation of income and capital within and…