Proceedings pursuant to CPLR article 78 (transferred to this court by order of the Supreme Court at Special Term, entered in Albany County) to review determinations of the State Tax Commission, which sustained sales and use tax assessments imposed pursuant to section 1105 of the Tax Law. The petitioners, New York Life Insurance Company (hereafter New York), and Metropolitan Life Insurance Company (hereafter Metropolitan), are engaged in the business of selli…
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