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  5. 28 N.Y.2d 179 (1971)
 

MTR. INTER-CO. TIT. v. STATE TAX COMM.

28 N.Y.2d 179 (1971)

In the Matter of Inter-County Title Guaranty and Mortgage Company, Appellant, v. State Tax Commission, Respondent.

Court of Appeals of the State of New York.

Decided April 21, 1971.

Attorney(s) appearing for the Case

John P. Walsh for appellant.

Louis J. Lefkowitz, Attorney-General (Vincent P. Molineaux and Ruth Kessler Toch of counsel), for respondent.

Arthur F. Gaynor for Security Title and Guaranty Company, amicus curiae.

Judges BURKE, SCILEPPI, BERGAN, BREITEL, JASEN and GIBSON concur.

Chief Judge FULD.

Section 187 of the Tax Law requires title insurance companies to pay a franchise tax on "gross direct premiums" written on risks located in this State. This appeal, here by our permission, requires us to say whether the tax may be levied on fees charged by the petitioner for title examinations made as a preliminary to the issuance of title insurance.

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