For the years 1961 and 1962, petitioner filed New York State resident income tax returns, but did not file unincorporated business tax returns. On October 25, 1965, respondent issued a notice of deficiency and a statement of audit changes which determined petitioner's liability for unincorporated business tax and interest for the years in question to be $1,377.85. Thereafter, petitioner filed with respondent a petition for redetermination of said deficiency, and he claims...
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