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MATTER OF AMERICAN AIRLINES, INC. v. NEW YORK CITY TAX APPEALS TRIBUNAL

3353.

77 A.D.3d 478 (2010)

910 N.Y.S.2d 417

In the Matter of AMERICAN AIRLINES, INC., Petitioner, v. NEW YORK CITY TAX APPEALS TRIBUNAL et al., Respondents.

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

Decided October 14, 2010.

The Tribunal's decision that petitioner was not a permanent resident with respect to the hotel rooms it occupied for less than 180 consecutive days is based on a rational interpretation of the relevant statutory provisions (see Matter of Moran Towing & Transp. Co. v New York State Tax Commn., 72 N.Y.2d 166, 173 [1988]). The Administrative Code of the City of New York provides that, except "upon a permanent resident" (§...

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