OPINION OF THE COURT
CARDONA, P. J.
This proceeding involves a challenge by petitioners, Matthew J. Domber (hereinafter Domber) and his wife, nonresidents of New York, to a determination of respondent Tax Appeals Tribunal assessing additional personal income tax based upon certain income distributed to Domber from a New York law partnership during the 1989 tax year. The Tribunal concluded that the income was improperly allocated to non-New York sources....
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