Judgment affirmed, with costs, for the reasons stated in the opinion by Justice Robert G. Main at the Appellate Division ( 114 A.D.2d 138; see also, Matter of Wurlitzer Co. v State Tax Commn., 35 N.Y.2d 100; Matter of Campbell Sales Co. v New York State Tax Commn., 68 N.Y.2d 617).
Concur: Chief Judge WACHTLER and Judges MEYER, SIMONS, KAYE, ALEXANDER, TITONE and HANCOCK, JR.