Crew III, J. P.
During the time period in issue, petitioner Elias H. Attea, Jr. (hereinafter Attea), a resident of Tennessee and a licensed Indian trader, owned and operated a wholesale tobacco products business under the name of J.R. Attea Wholesale. For tax year 1990, petitioner and his spouse, petitioner Karen Attea, filed a joint nonresident income tax return reporting a Federal adjusted gross income of $995,264, of which $117,946 was allocated to New York. For...
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