On May 4, 1982, a determination of a tax deficiency was made against the petitioners in the sum of $6,955.59 by appellant New York City Department of Finance. The final determination, dated January 3, 1983, was mailed to petitioners on January 3, 1983 by certified mail, receipt of which was acknowledged on January 13, 1983. Petitioners then moved by an order to show cause, dated May 4, 1983, for an order or judgment pursuant to CPLR article 78 directing a prompt judicial...
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