Church Charity Foundation v. State Tax Commission

— Proceeding pursuant to CPLR article 78 (transferred to this court by order of the Supreme Court at Special Term, entered in Albany County) to review a determination of the State Tax Commission which sustained a mortgage recording tax imposed pursuant to article 11 of the Tax Law. Petitioner, Church Charity Foundation of Long Island, is concededly primarily a voluntary nonprofit hospital corporation. Although it is singular corporation it operates various facilities under different operating licenses, including St. John’s Episcopal Hospital in Brooklyn, St. John’s Smithtown Hospital, St.…