Denial of a credit under the retaliatory tax imposed by Insurance Law § 1112 for amounts paid for commercial rent tax pursuant to Administrative Code of the City of New York § 11-701 et seq. is in accord with the purpose of the statute, and thus constitutes a rational interpretation of the statutory scheme that should not be disturbed by this court. Among other things, we are persuaded, as was the IAS court, that the commercial rent tax imposed by the City...
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