MATTER OF ALAN DREY CO., INC. v. State Tax Comm'n

— 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 sales and use tax assessment imposed under articles 28 and 29 of the Tax Law. The petitioner is admittedly engaged as a broker or middleman bringing together buyers and sellers of lists of names known as mailing lists. In the present case, the "lists” were limited to Cheshire (gummed) name labels and magnetic tapes of names. The transaction considered in this proceeding constituted…