
    In the Matter of Blue Spruce Farms, Inc., Appellant, v New York State Tax Commission, Respondent.
    Argued November 16, 1984;
    decided December 13, 1984
    
      APPEARANCES OF COUNSEL
    
      Richard V. D’Alessandro for appellant.
    
      Robert Abrams, Attorney-General (Nancy A. Spiegel and Peter H. Schiff of counsel), for respondent.
   OPINION OF THE COURT

Order affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (99 AD2d 867).

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