Prior to 1986, and at all times relevant to this proceeding, petitioners were domiciled in Connecticut and maintained an apartment in New York City. Although petitioners' nonresident New York State income tax return for tax year 1983 reflected a Connecticut address, the W-2 forms attached thereto bore a New York City address. Noting this apparent inconsistency, the Audit Division of the Department of Taxation and Finance requested a clarification...
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