Xerox Corp. v. New York State Tax Appeals Tribunal

Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law § 2016) to review a determination of respondent Tax Appeals Tribunal which denied petitioner’s request for a refund of corporate franchise tax imposed under Tax Law article 9-A.

Petitioner is a New York corporation that manufactures and sells office equipment and supplies and provides related services. It sells its goods and services outright and, more commonly, through a variety of contractual pay-over-time financing agreements that bundle the goods, services and/or supplies for its governmental and…