LARIO, J.T.C.
Plaintiffs, Daniel and Phyllis Goffredo, appealed from deficiencies assessed against them by the Director, Division of Taxation under the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1, et seq. (act), for the tax years 1981, 1982 and 1983.
The primary question raised by this appeal is whether plaintiffs, who owned homes in New Jersey and Pennsylvania but were employed and spent the majority of the time for the years
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