Peters, J.
Petitioner and her husband, filing joint personal income tax returns, were audited for the years 1994 through 1996. On January 19, 1999, they were issued a notice of deficiency assessing additional taxes, plus penalties and interest, for a total amount of $3,367,602.31, as a result of a finding that they had improperly filed as nonresidents. The New York State Bureau of Conciliation and Mediation upheld the notice of deficiency after a conference and a...
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