Petitioners, one of whom is the sole shareholder of Golden Hue Manufacturing, Inc., a subchapter "S" corporation that operates a Dunkin Donuts franchise in Dutchess County, claimed an investment tax credit (see, Tax Law § 606 [a]) against their personal income tax for 1986, 1987 and 1988 based on the purchase price of certain equipment used to make doughnuts and other baked goods. The Department of Taxation and Finance disallowed...
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