On December 11, 1972, petitioner Jack R. Cooper and his now deceased wife, Josephine Cooper, of whose estate Jack Cooper and Norris J. Bishton, Jr., are executors, filed their joint New York State resident income tax return for the year 1971. Although they paid the taxes due and owing, a petition for redetermination or refund accompanied this late filing, in which petitioners claimed to be nonresidents and nondomicilaries of the State in 1971. On September 24, 1973, the Income...
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