During 1966, 1967 and 1968, the substantial portion of petitioner's income was derived from commissions he received as trustee of about 15 trusts involving four families. He filed New York State resident income tax returns for those years, but did not file unincorporated business tax returns. Following a hearing, the State Tax Commission concluded that petitioner's activities in managing the trusts constituted the carrying on of an unincorporated business subject to the unincorporated...
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