Petitioner is a Delaware corporation having only a statutory office there. Its principal and only office and place of business is in New York City. Section 209 of the Tax Law provides for a franchise tax upon both domestic and foreign corporations. Section 210 of the Tax Law provides for the allocation of income upon which the tax is payable in the State of New York under various circumstances, but we are concerned here only with that portion of section 210 (subd. 3, par...
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