During the relevant tax year, petitioner resided in New Jersey. He worked as a management consultant for a firm with offices in New York. The firm allowed petitioner to perform his paper work at home and, consequently, petitioner worked 194 of 247 working days in New Jersey. He paid New York income tax on the 53 days worked in New York. Respondent assessed an additional $967.60 after its determination that all income was subject to New York tax. Petitioner argued before respondent...
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