An initial audit of petitioner's 1982 and 1983 New York State and New York City income tax returns, conducted within the three-year Statute of Limitations period (see, Tax Law § 683 [a]), did not result in the issuance of a notice of deficiency, although, according to petitioner, some errors were discovered, and additional taxes were agreed to and paid. Because the auditor was subsequently found guilty of having accepted bribes...
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