Petitioner filed joint New York State tax returns with his wife for the years 1973, 1974 and 1975. Although these returns stated that petitioner had business income whose source was described as insurance or insurance/accounting, the section for unincorporated business income tax was left blank. Subsequently, respondent, in 1978, assessed unincorporated business taxes for 1973 to 1975 on petitioner's insurance/accounting business income and issued notices of deficiency for...
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