MEMORANDUM.
The order of the Appellate Division should be affirmed, with costs, for the reasons stated in the memorandum of that court relative to the application of subdivision 3 of section 470 of the Tax Law. Inasmuch as the determination of the State Tax Commission was not predicated on the provisions of section 471-a we intimate no views as to the applicability of that section.
Chief Judge COOKE and Judges JASEN, GABRIELLI, JONES, WACHTLER, FUCHSBERG and MEYER concur.
Order affirmed, with costs, in a memorandum.