
    In the Matter of James MacLean, Appellant, v New York State Tax Commission, Respondent.
    Argued March 18, 1980;
    decided April 22, 1980
    
      APPEARANCES OF COUNSEL
    
      Victor M. Meyers for appellant.
    
      Robert Abrams, Attorney-General (Maurice K. Peaslee and Shirley Adelson Siegel of counsel), for respondent.
   OPINION OF THE COURT

Judgment affirmed, with costs, for reasons stated in the memorandum at the Appellate Division (69 AD2d 951).

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