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  5. 69 N.Y.2d 281 (1987)
 

CONT'L BANK v. NYC

69 N.Y.2d 281 (1987)

In the Matter of Continental Bank International, Appellant, v. City of New York Department of Finance, Respondent.

Court of Appeals of the State of New York.

Decided February 19, 1987.

Attorney(s) appearing for the Case

Edward W. Keane, Willard B. Taylor, H. Rodgin Cohen and Theodore Edelman for appellant.

Frederick A. O. Schwarz, Jr., Corporation Counsel (Joseph V. Hamilton, Jr., Edith I. Spivack, Gale Zareko and James F. Eller of counsel), for respondent.

Richard C. Pugh, Jo-Ann Horn and Michael G. DeAngelis for Security Pacific International Bank and others, amici curiae.

Chief Judge WACHTLER and Judges SIMONS, KAYE, ALEXANDER, HANCOCK, JR., and BELLACOSA concur.

TITONE, J.

The question before us is whether an international bank chartered by the Federal Government pursuant to the Edge Act (12 USC §§ 611-632),1 having a home office in another State and a branch office in New York City is immune from New York taxation. Inasmuch as we conclude that Edge Act banks are not Federal instrumentalities entitled to constitutional

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