There is no dispute as to any material factual issue. The petitioner was the president of Gamma Electrical Contractors and Consultants, Inc. (Gamma) which became bankrupt in 1973. On July 29, 1974 the State Tax Commission issued a statement of deficiency against the petitioner equal to the amount of New York State withholding taxes due from Gamma for the periods May 1, 1972 to June 30, 1972; July 1, 1972 to December 30, 1972 and from January 1, 1973 to June 29, 1973. The...
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