The pertinent provision of the statute under which the questioned assessment was made (Tax Law, art. 9-B, § 219-q, subd. 8) is as follows: "The acquisition by a taxpayer directly or indirectly, of the assets or franchises of another taxpayer or national bank shall be deemed a merger for the purposes of this section." The aforesaid statute further provides that in the event of a merger of a State banking institution and a national bank the resulting taxpayer shall be...
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