
    In the Matter of F. W. Woolworth Co., Appellant, v New York State Tax Commission, Respondent.
    Argued March 18,1988;
    decided April 21, 1988
    
      APPEARANCES OF COUNSEL
    
      Michael Bray for appellant.
    
      Robert Abrams, Attorney-General (Francis V. Dow, O. Peter Sherwood and Peter H. Schiff of counsel), for respondent.
   OPINION OF THE COURT

Judgment affirmed, with costs, for the reasons stated in the memorandum at the Appellate Division (126 AD2d 876).

Concur: Chief Judge Wachtler and Judges Simons, Kaye, Alexander, Titone, Hancock, Jr., and Bellacosa.  