Legal Opinion

Bankers Trust Corp. v. Tax Appeals Tribunal

Appellate Division of the Supreme Court of the State of New York

Decided March 13, 2012Published

1Opinion of the Court

Decision of respondent New York City Tax Appeals Tribunal, dated April 8, 2010, affirming an administrative determination that petitioner is not entitled to a 17% interest deduction for the interest income it received from its third- and fourth-tier indirect subsidiaries, unanimously confirmed, the petition denied, and the proceeding brought pursuant to CPLR article 78 and New York City Charter § 171, commenced in this Court pursuant to CPLR 506 (b) (4), dismissed, without costs.

Respondent’s decision that petitioner was not the beneficial owner of two indirect subsidiaries, BT Trust Holdings…

2Cases cited4 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. American Telephone & Telegraph Co. v. State Tax CommissionNew York Court of Appeals · 1984
  4. Hilton Hotels Corp. v. Commissioner of FinanceAppellate Division of the Supreme Court of the State of New York · 1995

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