New York Court of Appeals

In the Matter of American Telephone and Telegraph Company, Appellant-Respondent v. State Tax Commission

March 29, 198461 N.Y.2d 393

Summary

The Court held that AT&T's advances to subsidiaries and its temporary cash investment account constitute assets employed in New York and are taxable under section 183, but interest and dividends receivable but not yet paid are not taxable under section 183, and interest income from out-of-state obligors is not taxable earnings from a source within New York under section 184. The modified judgment of the Appellate Division was affirmed.