William H. Tripp, now deceased, and his wife filed New York State income tax resident returns for the years 1962, 1963 and 1964, and he also filed unincorporated business tax returns for the same years in which he omitted from income reported the net income he derived from his activities as a yacht designer during the tax years in question. In September, 1966 respondent issued a statement of audit changes and a notice of deficiency which determined decedent's liability for...
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