United States Steel Corp. v. Gerosa

Petitioner, in this article 78 proceeding, seeks a review of respondent’s determination of petitioner’s liability for business tax imposed pursuant to title B of chapter 46 of the Administrative Code of the City of New York. In order to bring this matter into proper focus a short history of prior proceedings is advisable.

*315Petitioner, a New Jersey corporation, is a holding company with its principal place of business located in the City of New York. Most of its income, for the privilege years in question, consisted of dividends and interest from some 68 controlled subsidiaries. In those years,…