¶ During the years in question, 1973, 1974 and 1975, petitioner was a partner in a New York City stockbrokerage firm. He also earned income for performing other brokerage services. On April 12, 1978, the State Department of Taxation and Finance (department) issued a notice of deficiency against petitioner indicating additional personal and unincorporated business income taxes due of $6,425, along with interest and penalties of $4,490.45. The taxes due consisted of personal...
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