MATTER OF AM. COM. TECH. v. ST. OF N.Y. TAX APP

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.