Petitioner Stanley Bachman was an equal partner with his brother in Bachman Wholesale, a Rochester, New York, based concern engaged in the purchase and resale of surplus material and equipment. In 1968, he became a resident of Washington, D. C., where the partnership opened an office. Though he continued to receive his annual distributive share from the partnership, he failed to file a New York State nonresident return for the years 1969-1975. On March 28, 1977, the Department...
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