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  5. 43 N.Y.2d 425 (1977)
 

CITIBANK v. CITY FIN. ADMIN.

43 N.Y.2d 425 (1977)

Citibank, N. A., Appellant, v. City of New York Finance Administration, Respondent. Chase Manhattan Bank, N. A., Appellant, v. Finance Administration of the City of New York et al., Respondents.

Court of Appeals of the State of New York.

Decided December 21, 1977.

Attorney(s) appearing for the Case

J. Paul McGrath, Bob D. Mannis, W. Foster Wollen and John T. Klug for appellants.

W. Bernard Richland, Corporation Counsel (Samuel J. Warms of counsel), for respondents.

Chief Judge BREITEL and Judges GABRIELLI and COOKE concur with Judge FUCHSBERG; Judge JONES dissents and votes to reverse in a separate opinion in which Judges JASEN and WACHTLER concur.

FUCHSBERG, J.

The two petitioners, who each lease and occupy premises in the City of New York, where they have their principal places of business, are banking associations chartered under the laws of the national Government. In separate proceedings, brought under CPLR article 78 and considered together, they challenge imposition upon them of the city's commercial rent tax (Administrative Code of City of New York...

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