New York Supreme Court July 24, 1987 (Lincoln First Commercial Corp. v. New York State Tax Commission)

OPINION OF THE COURT

David B. Saxe, J.

Plaintiff moves for partial summary judgment pursuant to *479CPLR 3212 (e). Defendants New York State Tax Commission (State) and City of New York Department of Taxation and Finance (City) informally cross-move for summary judgment.

Plaintiff is a commercial lending corporation which advanced funds to Joseph Schrager, Inc.