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TEXAS E. v. APPEALS TRIBUNAL

260 A.D.2d 127 (1999)

699 N.Y.S.2d 560

In the Matter of TEXAS EASTERN TRANSMISSION CORPORATION, Petitioner, v. TAX APPEALS TRIBUNAL et al., Respondents.

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

December 9, 1999.

Attorney(s) appearing for the Case

Harold M. Seidel, Morristown, New Jersey, and LeBoeuf, Lamb, Greene & MacRae, L. L. P., Albany (Frederick B. Galt of counsel), for petitioner.

Eliot Spitzer, Attorney General, Albany (Andrew D. Bing of counsel), for respondents.

SPAIN, CARPINELLO, GRAFFEO and MUGGLIN, JJ., concur.

OPINION OF THE COURT

CREW III, J. P.

The parties have stipulated to the relevant facts. During the years in question (1989, 1990 and 1991) petitioner, a Delaware corporation with its principal office and place of business in Houston, Texas, owned and operated an interstate natural gas pipeline system that extended from Texas to the northeast and midwest United States and spanned some 1,900 miles. The length of the pipeline in New York, which terminated on...

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