Citation Codes Equivalent Citations citation codes Attorney(S) Emil Levin Harry Merwin for Louis J. Lefkowitz, Attorney-General ( Robert W. Bush Paxton Blair of counsel), for See more information ... Smart Summary Please sign up to generate summary. In the Matter of 6 E. 112TH STREET CORP. et al., Appellants, against STATE TAX COMMISSION OF THE STATE OF NEW YORK, Respondent. Order affirmed, with costs; no opinion. Concur: Chief Judge DESMOND and Judges DYE, VAN VOORHIS and FOSTER. Judges FULD, FROESSEL and BURKE dissent and vote to reverse upon the ground that, by their renting of a few furnished apartments without accompanying services of any kind, petitioners did not thereby engage in any other business nor cease to be "wholly engaged" in the business of real estate and "in holding title to real estate for itself", within the meaning of section 182 of the Tax Law and, accordingly, the commission's reclassification of petitioners is arbitrary and unreasonable.