In 1977, petitioners received a notice of deficiency of some $3,480 for their 1975 income tax based upon the Income Tax Bureau's determination that they became permanent New York residents on May 1, 1975. They then petitioned for a redetermination of the deficiency and a prehearing conference was held in April, 1979. The conference did not resolve the dispute over the date upon which petitioners became permanent State residents. In September, 1979, the Tax Commission notified...
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