In 1976, the Department of Taxation and Finance issued a statement of audit changes against petitioner finding additional personal income taxes and unincorporated business taxes due for the years 1972, 1973 and 1974. Fraud penalties pursuant to Tax Law § 685 (e) were also imposed. Consequently, a notice of deficiency for the above years was issued in the amount of $47,237.26. Petitioner applied for a redetermination and, in due course...
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