
    In the Matter of Myron Fass, Respondent, v Tax Commission of the State of New York, Appellant.
    Argued May 27, 1980;
    decided June 24, 1980
    
      APPEARANCES OF COUNSEL
    
      Robert Abrams, Attorney-General (Francis V. Dow and Shirley Adelson Siegel of counsel), for appellant.
    
      Eli Uncyk and Marc L. Zoldessy for respondent.
   OPINION OF THE COURT

Judgment affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (68 AD2d 977).

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