Richmond Constructors v. Tishelman

OPINION OF THE COURT

Sandler, J.

Richmond Constructors is a joint venture entered into by five corporate partners for the purpose of performing a construction contract with the City of New York to build a sewer tunnel. This was the only job done by Richmond and was its sole source of revenue. At issue here is the city unincorporated business tax on the net income from that contract.

*415Richmond’s unincorporated business tax return showed no tax liability on the entire net income from the venture, $7,226,074, the total of the corporate partners’ distributive shares, because Richmond claimed an…