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MTR OF WALSH v. TAX TRIBUNAL

196 A.D.2d 367 (1994)

In the Matter of Lawrence E. Walsh et al., Petitioners, v. Tax Appeals Tribunal of the State of New York et al., Respondents

Appellate Division of the Supreme Court of the State of New York, Third Department.

March 24, 1994

Attorney(s) appearing for the Case

Davis, Polk & Wardwell, New York City (John A. Corry and Leslie J. Altus of counsel), and DeGraff, Foy, Holt-Harris & Mealey, Albany (James H. Tulley, Jr., and Peter G. Barber of counsel), for petitioners.

G. Oliver Koppell, Attorney-General, Albany (Daniel Smirlock and Nancy A. Spiegel of counsel), for Commissioner of Taxation and Finance of the State of New York, respondent.

MIKOLL, J. P., WHITE and YESAWICH JR., JJ., concur.

CASEY, J.

In 1985, the Legislature provided for the establishment of a three-month tax amnesty program during which any penalties would be waived upon a taxpayer's application and payment of designated taxes plus interest, and no civil, criminal or administrative action or proceeding could be brought against the taxpayer relating to the designated taxes (L 1985, ch 66, § 1 [a], [b]). Petitioner Lawrence...

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