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MATTER OF GERSON LEHRMAN GROUP, INC. v. NEW YORK CITY TAX APPEALS TRIB.

Appeal No. 13511. Case No. 2019-4129.

193 A.D.3d 452 (2021)

148 N.Y.S.3d 4

2021 NY Slip Op 02102

In the Matter of Gerson Lehrman Group, Inc., Petitioner, v. New York City Tax Appeals Tribunal, Respondent.

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

Decided April 6, 2021.

Attorney(s) appearing for the Case

Sidley Austin LLP, New York ( Richard A. Leavy of counsel), for petitioner.

James E. Johnson , Corporation Counsel, New York ( Martin I. Nussbaum of counsel), for respondent.

Concur—Gische, J.P., Kapnick, Oing, Moulton, JJ.

This article 78 petition concerns the proper method for calculating petitioner's receipts for purposes of determining its general corporation tax and tax obligation to the City. During the tax years at issue,* Administrative Code of City of NY § 11-604 allocated a taxpayer's business income to the City based on the average of the percentages within the City that a taxpayer's property, receipts and payroll bear to the total of the taxpayer...

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