In 1983, the Department of Taxation and Finance issued two notices of deficiency totaling $16,428 to Fred M. Sigman (hereinafter decedent) for the tax years 1979 to 1981. The assessments were challenged and a hearing was held before the State Tax Commission. The issues were (1) whether decedent was a New York resident for the years in question and, if so, (2) whether he was eligible for the resident...
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