Carpinello, J.
Albany Capitaland Enterprises, Inc. (hereinafter Capitaland) is a closely held corporation in the business of leasing taxicabs to operators for a daily fee and providing them with radio dispatch services. The taxicabs are actually owned by Capitaland's wholly owned subsidiary corporations. As of April 1990, Capitaland leased employees from American Payroll Network, an employee leasing service. Under the employee leasing agreement, American Payroll agreed...
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