The opinion of the court was delivered by SCHETTINO, J.
Petitioner, Walnut Realty Company, (hereafter referred to as Walnut) seeks to reverse a judgment of the Division of Tax Appeals which held the company subject to franchise taxes at the rates provided for a "financial business" rather than at the lower rates specified for a general business corporation. While the appeal was pending before the Appellate Division, we certified the matter on our own motion. R...
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