Rockefeller Center, Inc. v. Bragalini

This is an article 78 proceeding to review a determination of the State Tax Commission denying petitioner’s application for a partial refund of a mortgage recording tax. The mortgage, executed by Roeknom, Inc., a wholly owned subsidiary of petitioner, as mortgagor, to the Equitable Life Assurance Society, as mortgagee, covers a sublease of property at the corner of West 49th Street and the Avenue of the Americas, in New Tork City, and was given to secure the principal sum of $9,300,000 advanced, or to be advanced, in accordance with a building loan agreement. Before the mortgage was executed…