Petitioners are five nonresident members of a law firm practicing in both New York City and Washington, D.C., and four of their spouses. They seek annulment of a determination made after a consolidated small claims hearing which upheld notices of deficiency and additional assessments of their 1974 and 1975 New York State nonresident income tax returns. The sole issue in this transferred CPLR article 78 proceeding is whether respondent's application of a three-factor method...
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