
    [633 NE2d 479, 611 NYS2d 125]
    In the Matter of American Communications Technology, Inc., et al., Petitioners, and David Meyers et al., Appellants, v State of New York Tax Appeals Tribunal et al., Respondents.
    Argued January 12, 1994;
    decided February 10, 1994
    
      APPEARANCES OF COUNSEL
    
      Scher & Scher, P. C., Great Neck (Robert A. Scher and Daniel J. Scher of counsel), for appellants.
    
      G. Oliver Koppell, Attorney-General, Albany (Nancy A. Spiegel, Jerry Boone and Peter H. Schiff of counsel), for James W. Wetzler, respondent.
   OPINION OF THE COURT

Judgment affirmed, with costs, for the reasons stated in the opinion by Justice A. Franklin Mahoney at the Appellate Division (185 AD2d 79).

Concur: Chief Judge Kaye and Judges Simons, Bellacosa, Smith and Ciparick. Taking no part: Judges Titone and Levine.  