During the years 1968 through 1973, petitioner Leonard Rosenblum was engaged in selling lingerie for Lisette, a division of Athlone Industries, Inc., and loungewear for Lisanne, Inc., but in connection with these activities he filed no unincorporated business tax returns for the years in question. Subsequently, following a hearing and by decision dated April 27, 1977, the State Tax Commission determined that his activities constituted the carrying on of an unincorporated...
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