OPINION OF THE COURT
Judgment affirmed, with costs, for the reasons stated in the opinion by Justice Robert G. Main at the Appellate Division (114 AD2d 138; see also, Matter of Wurlitzer Co. v State Tax Commn., 35 NY2d 100; Matter of Campbell Sales Co. v New York State Tax Commn., 68 NY2d 617). Concur: Chief Judge Wachtler and Judges Meyer, Simons, Kaye, Alexander, Titone and Hancock, Jr.