
    In the Matter of Petroleum Sales and Service, Inc., Appellant, v Robert W. Bouchard et al., Constituting the State Tax Commission, Respondents.
    Argued November 12, 1984;
    decided December 11, 1984
    
      APPEARANCES OF COUNSEL
    
      Susan C. Goldberg, Donald J. Egan and Gary M. Kanaley for appellant.
    
      Robert Abrams, Attorney-General (Francis V. Dow and Peter H. Schiff of counsel), for respondents.
   OPINION OF THE COURT

Judgment affirmed, with costs, for reasons stated in the memorandum of the Appellate Division (98 AD2d 882).

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