This is a CPLR article 78 proceeding in which petitioners seek an order: (1) permitting this proceeding to be maintained as a class action; and (2) a judgment reversing respondent's decision of November 8, 1985 which denied petitioners' request for a redetermination of a deficiency or for refund of personal income tax for the year 1981, on the grounds that the respondent's decision is arbitrary...
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