The tax deficiency assessed against petitioners was calculated on the basis they were New York residents throughout 1973. The amount thereof was not disputed, but petitioners asserted that no additional tax was due because they had effected a change in their domicile to the State of Florida (see Tax Law, § 654, subd [a]; § 605, subd [a], par [1]). Their contention was rejected following a hearing, and the sole issue raised by this proceeding is whether substantial...
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