MATTER OF DELMHORST v. STATE TAX COMMISSION

On review of submissions pursuant to rule 500.2 (b) of the Rules of the Court of Appeals (22 N.Y.CRR 500.2 [g]), judgment affirmed, with costs, for the reasons stated in the memorandum of the Appellate Division ( 92 A.D.2d 981).

Concur: Chief Judge COOKE and Judges JASEN, JONES, WACHTLER, MEYER and SIMONS.