MEMORANDUM.
The judgment of the Appellate Division should be affirmed, with costs.
Although the proof in the record would also have supported a contrary conclusion, we cannot say that there is not substantial evidence to sustain the determination made by the State Tax Commission.
Chief Judge COOKE and Judges JASEN, GABRIELLI, JONES, WACHTLER, FUCHSBERG and MEYER concur in memorandum.
Judgment affirmed.