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In the Matter of AMERICAN COMMUNICATIONS TECHNOLOGY, INC., et al., Petitioners, and DAVID MEYERS et al., Appellants, v. STATE OF NEW YORK TAX APPEALS TRIBUNAL et al., Respondents.

Judgment affirmed, with costs, for the reasons stated in the opinion by Justice A. Franklin Mahoney at the Appellate Division ( 185 A.D.2d 79).

Concur: Chief Judge KAYE and Judges SIMONS, BELLACOSA, SMITH and CIPARICK. Taking no part: Judges TITONE and LEVINE.

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MATTER OF AM. COM. TECH. v. ST. OF N.Y. TAX APP
(Feb 10, 1994)