New York Court of Appeals October 27, 1981 (Vogt v. Tully)

OPINION OF THE COURT

Jones, J.

Inasmuch as there is no substantial evidence in the record to support the State Tax Commission’s finding that Endeavor Car Company, a limited partnership engaged in the financing and leasing of railroad tank cars, was not carrying on a business in New York State, the commission’s determination, dependent on that finding, that the distributive share of partnership