
    In the Matter of Russell T. Weil et al., Appellants, v Roderick G. W. Chu et al., Constituting the New York State Tax Commission, Respondents.
    Argued September 10, 1987;
    decided October 15, 1987
    
      APPEARANCES OF COUNSEL
    
      Robert J. Hickey and Ernest V. Luzzatto for appellants.
    
      Robert Abrams, Attorney-General (Francis V Dow, O. Peter Sherwood and Peter H. Schiff of counsel), for respondents.
   OPINION OF THE COURT

Judgment affirmed, with costs, for the reasons stated in the memorandum at the Appellate Division (120 AD2d 781).

Concur: Chief Judge Wachtler and Judges Simons, Kaye, Alexander, Titone, Hancock, Jr., and Bellacosa.  