Allied Stores Corp. v. State Tax Commission

Kane, J. P.

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 respondent which sustained a sales and use tax assessment imposed under Tax Law articles 28 and 29.

This CPLR article 78 proceeding concerns a sales and use tax assessment imposed on petitioner as the result of its termination of two licensing agreements with John F. Davis Company, Inc. (Davis) in a document entitled "Purchase and Sale Agreement”, executed August 14, 1978.

Allied Stores is a corporation with divisions…