In August and September 1969, respondent issued notices of additional assessment of income taxes due for the tax years 1959, 1960 and 1961, based upon petitioners' failure to report audit changes in their joint Federal income tax returns for those years. Tax warrants were filed in Kings County on February 20, 1970 for the 1959 assessment and on June 15, 1970 for the 1960 and 1961 assessments. Transcripts of the warrants were subsequently filed...
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