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In the Matter of Fraydun Manocherian v. Tax Commission of the City of New York
OPINION OF THE COURT
Order reversed, with costs, petitioner’s motion for partial summary judgment denied, and certified question answered in the negative for the reasons stated in the dissenting memorandum by Justice Joseph P. Sullivan at the Appellate Division (185 AD2d 778, 778-784).
Concur: Chief Judge Kaye and Judges Simons, Titone, Hancock, Jr., Bellacosa and Smith. Taking no part: Judge Levine.