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MATTER OF STEVENSON v. NEW YORK STATE TAX APPEALS TRIB.

513540.

106 A.D.3d 1146 (2013)

964 N.Y.S.2d 707

In the Matter of ANN M. STEVENSON, Individually and as Executor of the Estate of MILTON F. STEVENSON, Deceased, Petitioner, v. NEW YORK STATE TAX APPEALS TRIBUNAL et al., Respondents.

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

Decided May 2, 2013.

McCarthy, J.

Milton F. Stevenson (hereinafter decedent) was the majority shareholder of Anoplate Corporation, which was certified pursuant to General Municipal Law article 18-B as a Qualified Empire Zone Enterprise (hereinafter QEZE). The corporation owned five parcels of property in the Onondaga County Sanitary District. Having elected to be treated as an S corporation, Anoplate's tax credits flowed through its shareholders (see Internal Revenue Code [26 USC...

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