MATTER OF RCA INT'L DEV. CORP. v. NEW YORK CITY TAX APPEALS TRIBUNAL


253 A.D.2d 392 (1998)

677 N.Y.S.2d 127

In the Matter of RCA International Development Corporation, Appellant, v. New York City Tax Appeals Tribunal et al., Respondents

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

August 20, 1998


Deferring to respondents' expertise with respect to whether particular instruments are "designed as a means of investment" within the meaning of former General Corporation Tax Regulation (20 NYCRR) § 3.31 (c), thereby qualifying as "other securities" within the meaning of former Administrative Code of the City of New York § R46-2.0 (4) (now § 11-602 [4]) entitled to the favorable tax treatment accorded income derived from investment capital (see,

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