Opinion
Submitted May 25, 1936
Decided May 26, 1936
MOTION to amend the remittitur granted and remittitur amended by adding thereto the following: "Upon the appeal herein the relator contended that the assessment of a tax against relator under sections 351 and 351-a of the Tax Law of the State of New York contravenes the Fourteenth Amendment of the Federal Constitution as an extraterritorial tax, and such question was presented and necessarily passed upon but not sustained by the court." (See 271 N.Y. 594.)