Legal Opinion
Prudential Insurance Co. of America v. Wrynn
New York Supreme Court
Decided April 16, 2012Published
1Opinion of the Court
OPINION OF THE COURT
Peter H. Moulton, J.
Petitioner Prudential Insurance Company of America (Prudential) brings this proceeding to annul respondent’s determination, dated November 18, 2010, denying it a refund and credit for retaliatory taxes. Petitioner maintains that the determina*429tion was affected by error of law, is arbitrary and capricious, and is an abuse of discretion. Respondent opposes the petition.1
The central issue in this proceeding is the interpretation of Tax Law § 1511 (b) and Insurance Law § 9109, as those statutes relate to retaliatory taxes. Retaliatory taxation is designed to…
2Cases cited12 opinions
- Western & Southern Life Ins. Co. v. State Bd. of Equalization of Cal.Supreme Court of the United States · 1981
- Kurcsics v. Merchants Mutual InsuranceNew York Court of Appeals · 1980
- Roberts v. Tishman Speyer Properties, L.P.New York Court of Appeals · 2009
- MATTER OF GUARDIAN LIFE INS. CO. v. ChapmanNew York Court of Appeals · 1951
- Roberts v. Tishman Speyer Properties, L.P.Appellate Division of the Supreme Court of the State of New York · 2009
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