Administrative Code of the City of New York § 11-530 (a) provides that a taxpayer's application to review an unincorporated business income tax determination made by the Commissioner of Finance shall be made "within four months after notice of the decision is sent by certified or registered mail to the taxpayer." The determination which petitioner seeks to contest was mailed on January 30, 1991. Since he did not commence this proceeding until June 3, 1991, it was properly...
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