On May 8, 1971, in Manhattan, the petitioners began doing business as a medical clinic to perform abortions. In 1977, the respondent audited petitioners concerning their compliance with the City of New York's unincorporated business income tax (UBIT). As a result of that audit, inter alia, petitioners were assessed a tax deficiency for the period May 8, 1971 through December 31, 1972. Subsequently, petitioners timely submitted a petition for redetermination of the...
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