635 Associates v. New York State Tax Commission

— 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 an unincorporated business tax deficiency. On or about April 1, 1968, petitioner was formed by the execution of a written joint venture agreement. Each of the 29 members contributed so that a total sum of $850,000 was raised and immediately loaned to the 59th and Madison Realty Corp. in exchange for a note and mortgage in that sum so that the latter might purchase the sublease of…