Petitioner is a New York insurance corporation. Prior to 1974, petitioner filed returns pursuant to Tax Law article 9A, the general corporation franchise tax statute. In 1974, the Legislature passed a franchise tax article dealing specifically with insurance companies (Tax Law art 33) which became effective for the taxable year beginning January 1, 1974. Since that time, petitioner has filed returns pursuant to this latter article. In 1973...
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