On October 16, 1980, respondent Commissioner of Finance of the City of New York issued a notice of deficiency against petitioner Airborne Freight Corporation under the New York City general corporation taxes for the period October 17, 1968 through December 31, 1978 in the amount of $547,005.72. The petitioner thereupon requested a hearing with regard to the assessment, which was duly conducted. At the hearing, it was established that Airborne was an air freight forwarder...
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