It is hereby ordered that the judgment so appealed from is unanimously modified on the law by granting judgment in favor of defendants as follows:
"It is adjudged and declared that 20 NYCRR 74.6 is valid and enforceable, and that defendant New York State Department of Taxation and Finance substantially complied with State Administrative Procedure Act §§ 201-a, 202-a and 202-b in promulgating that rule" and as modified the judgment is affirmed without costs...
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