Petitioner is a bank corporation subject to a corporate franchise tax (Tax Law art 32). In 1979, petitioner earned $2,146,649.73 in interest from various tax-exempt bonds issued by the State Housing Finance Agency (HFA bonds) and other tax-exempt municipal housing authority bonds (MHA bonds). Petitioner did not include this amount in its net income for purposes of calculating its corporate franchise tax. After an audit, the Department of Taxation...
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