Goodbody & Co. v. State Tax Commission

Proceeding *1026pursuant to CPLR article 78 (transferred to this court by-order of the Supreme Court at Special Term, entered in Albany County) to review respondent’s determination denying petitioner’s application for a refund of unincorporated business tax and imposed under Tax Law former article 23.*

The parties herein have stipulated to most of the underlying facts in this tax matter. Petitioner is the successor in interest to Goodbody & Company (Goodbody), a New York partnership engaged in the securities business as a broker and dealer. A clearing firm, Goodbody maintained its main office in…