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  5. 34 N.Y.2d 190 (1974)
 

MTR. OF PARSONS v. STATE TAX COMM.

34 N.Y.2d 190 (1974)

In the Matter of Lewis C. Parsons et al., Appellants, v. State Tax Commission, Respondent.

Court of Appeals of the State of New York.

Decided May 15, 1974.

Attorney(s) appearing for the Case

Andrew Halloran and John C. Lemery for Andrew Desmond Fitzgerald and Lewis C. Parsons, appellants.

Lambert L. Ginsberg for Paul Piedmont, appellant.

Louis J. Lefkowitz, Attorney-General (Vincent P. Molineaux and Ruth Kessler Toch of counsel), for respondent.

Chief Judge BREITEL and Judges JASEN, GABRIELLI, JONES, WACHTLER and STEVENS concur.

RABIN, J.

Petitioners are officers and directors of a corporation which properly filed its sales tax returns but failed to pay the amounts due. In its efforts to recover the taxes admittedly owing, the respondent State Tax Commission proceeded against petitioners individually by serving them with notices of determination and demand for the taxes and holding hearings...

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