Order dated February 20, 1956, insofar as appealed from, and order dated March 20, 1956 reversed, with $10 costs and disbursements, and matter remitted to the Special Term for further proceedings as indicated herein.
In the imposition, enforcement and collection of its excise taxes, the City of New York acts in its sovereign capacity. (Matter of Atlas Tel. Co., 273 N.Y. 51.) The limitation of time for filing claims as set forth in subdivision 7 of section 15...
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