During the taxable years in question, petitioner Joseph V. Giuliano (hereinafter Giuliano) and his partner, Vincent D'Acri, owned and operated petitioner Commons Deli, later renamed International Superette, a delicatessen and grocery store in The Bronx. The personal records of Giuliano and his wife, petitioner Joann Giuliano, were audited for the years 1977 through 1979 by the Audit Division of the Department of Taxation and Finance. The auditor...
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