
    In the Matter of James H. Sheils et al., Respondents, v State Tax Commission, Appellant.
    Argued January 13, 1981;
    
    decided February 12, 1981
    
    
      APPEARANCES OF COUNSEL
    
      Robert Abrams, Attorney-General (Wayne L. Benjamin and Shirley Adelson Siegel of counsel), for appellant.
    
      Alfred Wheeler, Sidney Smolowitz and Osias Biller for respondents.
   OPINION OF THE COURT

Order reversed, with costs, and the determinations of the State Tax Commission reinstated (see Matter of Gurney v Tully, 51 NY2d 818).

Concur: Chief Judge Cooke and Judges Jasen, Gabrielli, Jones, Wachtler, Fuchsberg and Meyer.  