
    In the Matter of American Credit Indemnity Company of New York, Respondent, v. State Tax Commission of State of New York, Appellant.
    Argued November 24, 1969;
    decided December 10, 1969.
    
      
      Louis J. Lefkowitz, Attorney-General (Vincent P. Molineaux and Ruth Kessler Toch of counsel), for appellant.
    
      Alfred J. Bohlinger, Alfred Miller and Victor M. Rosenzweig for respondent.
   Concur: Chief Judge Fuld and Judges Burke, Scileppi, Bergan, Breitel and Jasen. Taking no part: Judge Gibson.  