Petitioner, a domestic corporation, operated a number of parking lots and garages in New York City. The premises where each lot or garage was located were owned by one of five entities variously described as partnerships and joint ventures. Petitioner filed corporate franchise tax returns for fiscal years ending June 30, 1970 through June 30, 1974. On each return, petitioner was described as "dormant" and as having no net income. It paid only the minimum tax. After an audit...
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