Petitioner and his wife, Bridget B. Colleary, residents of New Jersey during the years 1967, 1968, 1970 and 1971, filed nonresident income tax returns for those years, deducting from their New York State income the income attributable to the days worked in New Jersey. The Income Tax Bureau, in disallowing the allocation, issued notices for deficiency totaling $25,236.36. Upon redetermination a penalty assessed for late filing was canceled. Petitioner was employed by a New...
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