Petitioners contend that the State Tax Commission erred in basing its determination on petitioners' failure to sustain their burden of proving their entitlement to an allocation of income due to the out-of-State services performed by petitioner Alvin Fischer (hereafter petitioner) on behalf of his employer. We agree in part with this claim.
Petitioner, a licensed engineer, is a principal in a firm which provides structural engineering services on a consultant basis...
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