Appellate Division of the Supreme Court of the State of New York May 21, 1987 (Colgate v. New York State Tax Commission)

Main, J. P.

Proceeding pursuant to CPLR article 78 (transferred to this court by order of the Supreme Court, entered in Albany County) to review a determination of respondent which sustained a gift tax deficiency assessment imposed under Tax Law article 26-A.

At issue in this proceeding is the valuation of certain gifts of stock made by petitioner and decedent in 1976.