Today we are required to again examine the scope of the exemption from unincorporated business tax created by subdivision (c) of section 703 of the Tax Law to determine whether petitioner has sustained his burden of proving his activities as a teacher, writer and lecturer constitute the practice of a profession (see 20 NYCRR 203.11), exempt from taxation. The facts are undisputed. During the tax years in issue, petitioner worked in the life insurance and business management...
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