McGraw-Hill, Inc. v. State Tax Commission

I respectfully dissent.

*376In Matter of Condé Nast Publs. v State Tax Commn. (51 AD2d 17, mot to dismiss appeal granted 39 NY2d 942), this court decided the precise issue before us, i.e., that under the provisions of Tax Law § 210 (3) (a) (2) (former [D]) petitioner’s receipts from magazine advertising contracts which were negotiated and handled in New York are totally New York receipts because they constitute business receipts earned within the State. Petitioner’s contention that Condé Nast is no longer applicable should be rejected. That contention is based on respondent’s promulgation in 1978…