
    In the Matter of American International Group, Inc., et al., Respondents, v James H. Tully, as President of the State Tax Commission, et al., Appellants.
    Argued May 2, 1983;
    decided June 7, 1983
    
      APPEARANCES OF COUNSEL
    
      Robert Abrams, Attorney-General (Maurice K. Peaslee and Peter H. Schiff of counsel), for appellants.
    
      Michael D. Brown and Christopher B. Hitchcock for respondents.
   OPINION OF THE COURT

Judgment affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (89 AD2d 687).

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