
    In the Matter of Leonard L. Franklin et al., Appellants, v New York State Tax Commission, Respondent.
    Argued November 20, 1984;
    decided December 13, 1984
    
      APPEARANCES OF COUNSEL
    
      Leonard L. Franklin, appellant pro se, and for Deborah Franklin, appellant.
    
      Robert Abrams, Attorney-General (Betsy Broder and Peter H. Schiff of counsel), for respondent.
   OPINION OF THE COURT

Order affirmed, with costs, for the reasons stated in the memorandum at the Appellate Division (101 AD2d 949).

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