The issue raised by this proceeding is whether respondent's determination that petitioner is not an employee but an independent contractor and thus subject to the unincorporated business tax under section 703 of the Tax Law is supported by substantial evidence. During the tax years in question, petitioner was a salesman carrying several lines of women's apparel. While under a written contract to Russel Taylor, Inc., a manufacturer of fall, fur-like coats, petitioner, (with...
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