
    In the Matter of Finserv Computer Corporation, Appellant, v James H. Tully et al., Constituting the New York State Tax Commission, Respondents.
    Argued February 17, 1984;
    decided March 20, 1984
    
      APPEARANCES OF COUNSEL
    
      E. Guy Roemer for appellant.
    
      Robert Abrams, Attorney-General (Francis V. Dow and Peter H. Schiff of counsel), for respondents.
   OPINION OF THE COURT

Order affirmed, with costs, for reasons stated in the opinion by Justice Howard A. Levine at the Appellate Division (94 AD2d 197).

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