New York Court of Appeals November 17, 1874 (People ex rel. Bank of Montreal v. Commissioners of Taxes & Assessments)

Rapallo, J.

The inquiry in this case is reduced to two questions. First, was the relator at the time of the impo*42sition.of the tax in question, doing business in the State of Hew York within the meaning of the act' of 1855; and, secondly, had it any sums invested in such business.