Petitioner, the president of a closed family corporation — 62% of stock owned by petitioner and 14% by his wife — was engaged in the manufacturing and supplying of marine machinery and parts, with his office in New York City. Such stock ownership is not necessarily a controlling factor in sustaining the action of the commission. In his tax return for the year in dispute [1951] he claimed allowance for 85 days work outside New York State. The commission determined...
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