MATTER OF PARKMED ASSOCS. v. New York State Tax Comm'n

OPINION OF THE COURT

Memorandum.

The judgment of the Appellate Division should be reversed, with costs, and the matter remitted to it for further proceedings in accordance with this memorandum.

Judicial review of an administrative determination is limited to the grounds invoked by the agency and a reviewing court which finds those grounds insufficient or improper may not sustain the determination by substituting what it deems to be a more appropriate or proper basis (Matter of Trump-Equitable Fifth Ave. Corp. v Gliedman, 57 NY2d 588, 593). Thus, the only question before the Appellate Division…