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MATTER OF WEBSTER v. TULLY

82 A.D.2d 976 (1981)

In the Matter of Richard B. Webster et al., Petitioners, v. James H. Tully, Jr., et al., Constituting The State Tax Commission, Respondents. (And Three Other Proceedings.)

Appellate Division of the Supreme Court of the State of New York, Third Department.

June 18, 1981

Petitioners1 are citizens of the United States and are also partners in a large international law partnership which maintains offices in New York City, Washington, D.C., Paris, France and Brussels, Belgium. During the years in question in these proceedings, 1969 and 1970, they resided and worked exclusively in Paris and Brussels. Notice of deficiency for personal income taxes were issues to petitioners for 1969 and 19702

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