MATTER OF ZINN v. TULLY

Judgment reversed, with costs, and the determination of the State Tax Commission reinstated for the reasons stated in the dissenting memorandum by former Justice LOUIS M. GREENBLOTT at the Appellate Division ( 77 A.D.2d 725, 726).

Chief Judge COOKE and Judges JASEN, JONES, FUCHSBERG and MEYER concur; Judges GABRIELLI and WACHTLER dissent and vote to affirm for the reasons stated in the majority memorandum at the Appellate Division ( 77 A.D.2d 725).