Judgment unanimously reversed on the law without costs and motion denied.
Memorandum:
Defendant entered into two interrelated written agreements with Western New York Geological Services, Inc. (WNYGS) which were apparently designed as tax shelters. Defendant paid $40,000 under the first agreement, whereby plaintiff was to apply for a maximum of 1,800 oil and gas leases between December 1980 and December 1981. In connection with the second agreement under which...
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