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OVERSEAS NAT. v. TAX COMM.

91 A.D.2d 162 (1983)

In the Matter of Overseas National Airways, Inc., Petitioner, v. State Tax Commission, Respondent

Appellate Division of the Supreme Court of the State of New York, Third Department.

January 20, 1983

Attorney(s) appearing for the Case

Breed, Abbott & Morgan (Edward H. Hein of counsel), for petitioner.

Robert Abrams, Attorney-General (Lawrence J. Logan and William J. Kogan of counsel), for respondent.

KANE, J. P., YESAWICH, JR., WEISS and LEVINE, JJ., concur.

MIKOLL, J.

Petitioner Overseas National Airways, Inc. (ONA), a Delaware corporation with corporate headquarters in New York, was engaged in the interstate and foreign air transport of passengers and cargo.1 None of its flights was made entirely within New York State. Petitioner was assessed franchise tax deficiencies for several years from 1968 through 1977 for taxes allegedly due under section 184 of the Tax Law. These deficiencies...

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