In 1986, pursuant to the issuance of various search warrants, the State Police seized $518,413.10 in U.S. currency from petitioner. As part of a stipulation with the Dutchess County District Attorney's office, petitioner forfeited $212,650.05 of such seized amount (see, CPLR 1311). On petitioner's 1986 tax return, he claimed only $153,310 as taxable income, $135,227 of which was "other income". The Department of Taxation and Finance...
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