Spain, J.
On January 1, 2003, a joint account was created for a number of wholly owned subsidiaries of KeySpan Corporation, including WDF, Inc. In April 2004, four additional employers were added and the tax rate was revised effective January 1, 2004. On February 11, 2005, KeySpan sold all of its WDF stock and, thereafter, WDF applied for removal from the joint account as of that date. The Commissioner of Labor denied the application explaining that the earliest dissolution...
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