Legal Opinion

UGP Properties, Inc. v. State Tax Commission

Appellate Division of the Supreme Court of the State of New York

Decided November 9, 1978PublishedCited by 8 opinions

1Opinion of the Court

OPINION OF THE COURT

Greenblott, J.

This proceeding raises two issues. The first is whether the petitioner has a regular place of business outside of New York, thereby entitling it to an allocation of business income or capital. The second is whether petitioner’s interest income on certificates of deposit issued by New York banks constitutes "business receipts earned within the State” for purposes of allocating its business capital.

Petitioner, a New York corporation, is a wholly owned subsidiary of Union General Properties, Ltd., a United Kingdom corporation with its office in London, England.…

2Cases cited2 opinions

  1. Archie Enterprises, Inc. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1977
  2. Birge Co. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1974

3Cited by8 opinions

  1. Del-Met Corp. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1984
  2. Labadie Sales Corp. v. New York City Deparment of FinanceAppellate Division of the Supreme Court of the State of New York · 1994
  3. Adirondack Steel Casting Co. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1985
  4. Psychological Corp. v. Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1984
  5. Alconox, Inc. v. New York State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1985

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