Sidenberg v. Chapman

This is a review under article 78 of the Civil Practice Act of a determination of the State Tax Commission’s assessment of unincorporated business taxes (Tax Law, art. 16-A), against relators for the years 1941-1944, inclusive.

As trustees under a will relators are owners of a nine-story hotel building in New York City, known as Hotel Theresa, on the ground floor of which are eleven separate store spaces unconnected with any part of the building designed and used for hotel purposes.

During the tax years in question the hotel was operated under the management of Gresham Management Company, a…