Legal Opinion
Sumitomo Trust & Banking Co. v. Commissioner of Taxation & Finance
Appellate Division of the Supreme Court of the State of New York
Decided February 1, 2001PublishedCited by 2 opinions
1Opinion of the Court
—Rose, 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 denied petitioner’s request for a refund of franchise taxes imposed under Tax Law article 32.
The sole issue in this proceeding is whether portions of the interest income attributable to certain loan pool certificates (hereinafter certificates)1 guaranteed by the United States Small Business Administration (hereinafter SBA) are deductible on the 1989-1991 Tax Law article 32 tax returns filed by petitioner, a New York chartered…
2Cases cited6 opinions
- Grace v. New York State Tax CommissionNew York Court of Appeals · 1975
- Smith v. DavisSupreme Court of the United States · 1944
- Rockford Life Insurance v. Illinois Department of RevenueSupreme Court of the United States · 1987
- People Ex Rel. Savings Bank of New London v. ColemanNew York Court of Appeals · 1892
- Brooklyn Union Gas Co. v. Commissioner of Taxation & FinanceAppellate Division of the Supreme Court of the State of New York · 1999
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Xo New York, Inc. v. Commissioner of Taxation & FinanceAppellate Division of the Supreme Court of the State of New York · 2008
- Schnell v. Commissioner of Taxation & FinanceAppellate Division of the Supreme Court of the State of New York · 2006