Petitioner operates a travel agency and a premium business selling notions. He and his wife filed combined personal income tax returns for the years 1970, 1971 and 1972 on which business income was divided equally between the two. Unincorporated business tax returns were not filed for those years. Respondent informed petitioner, by a notice of deficiency dated March 31, 1975, that income from his business activities was subject to unincorporated business tax, and for the...
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