The petitioners, husband and wife, filed joint New York State income tax returns for the years 1960 and 1961. Subsequently, they consented to a request by the respondents for an extension of the time within which to review the returns for those years by signing appropriate waivers. Thereafter, it was determined that a deficiency was owing and, upon assessment, which included interest from the date upon which tax payments for those years were due, the petitioners paid the...
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