Appellate Division of the Supreme Court of the State of New York October 28, 2004 (Sherwin-Williams Co. v. Tax Appeals Tribunal of the Department of Taxation & Finance)

OPINION OF THE COURT

Lahtinen, J.

Petitioner contends that respondents erred in requiring it to file a combined corporate franchise tax report in 1991 with two of its subsidiaries pursuant to Tax Law § 211. Petitioner is an Ohio corporation that does business in New York.