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SIEMENS CORP. v. TAX TRIBUNAL

217 A.D.2d 247 (1996)

635 N.Y.S.2d 806

In the Matter of Siemens Corporation, Formerly Siemens Capital Corporation, Petitioner, v. Tax Appeals Tribunal et al., Respondents

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

January 4, 1996

Attorney(s) appearing for the Case

Richard S. Payne, New York City, for petitioner.

Dennis C. Vacco, Attorney-General, Albany (Andrea Oser and Nancy A. Spiegel of counsel), for Commissioner of Taxation and Finance of the State of New York, respondent.

MIKOLL, J. P., MERCURE, CREW III and YESAWICH JR., JJ., concur.

SPAIN, J.

After an audit by the Audit Division of the Department of Taxation and Finance (hereinafter the Division), notices of deficiency were sent to petitioner claiming that it owed extra tax payments for interest income covering the years ending 1980, 1981 and 1983. Petitioner, a wholly owned subsidiary of Siemens Aktiengesellschaft (hereinafter Siemens AG.), with its principal place of business in New York...

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