¶1OPINION OF THE COURT
¶2Order reversed, with costs, and order and judgment of Supreme Court, New York County, reinstated for the reasons stated in the dissenting opinion of Justice Max Bloom at the Appellate Division (110 AD2d 1, 11-17; see also, Matter of Howard Johnson Co. v State Tax Commn., 65 NY2d 726).
¶3Concur: Chief Judge Wachtler and Judges Meyer, Simons, Kaye, Alexander, Titone and Hancock, Jr.