
    In the Matter of Arthur M. Delmhorst, as Executor of Berton J. Delmhorst, Deceased, et al., Respondents, v State Tax Commission, Appellant.
    Decided September 1, 1983
    
      APPEARANCES OF COUNSEL
    
      Robert Abrams, Attorney-General (Carl E. Stephan and Peter H. Schiff of counsel), for appellant.
    
      Louis Sternbach for respondent.
   OPINION OF THE COURT

On review of submissions pursuant to rule 500.2 (b) of the Rules of the Court of Appeals (22 NYCRR 500.2 [g]), judgment affirmed, with costs, for the reasons stated in the memorandum of the Appellate Division (92 AD2d 981).

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