Petitioner, a property and casualty insurer, is a Massachusetts corporation licensed to do business in New York. Petitioner is subject to the franchise tax provisions of Tax Law article 33 (Tax Law § 1500 [c]; § 1501 [a]). That law became effective with the 1974 taxable year (L 1974, ch 649, § 13), and imposed a franchise tax computed on the basis of petitioner's entire net income ...
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