CS Integrated, LLC v. Tax Appeals Tribunal
Appellate Division of the Supreme Court of the State of New York
1Opinion of the CourtMugglin, J.
Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law § 2016) to review a determination of respondent Tax Appeals Tribunal which sustained a corporation franchise tax assessment imposed under Tax Law article 9A.
Petitioner, a foreign corporation, provides cold storage and related services to the food products industry. In 1989, to service a retail supermarket chain (hereinafter Company A), petitioner built a refrigerated warehouse in the Town of Chester, Orange County. In 1991, Company A experienced cash flow problems and asked petitioner for a loan. Fearful of…
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