Peters, J.
During the relevant period, petitioner, a Florida resident, was the owner, president and sole shareholder of Coppola N.Y.C., Inc. (hereinafter CNYC), a beauty salon located in New York City. Following his discovery that the manager of CNYC's daily operations was embezzling funds and not paying many of the salon's bills or taxes, petitioner devised a settlement plan with the State and the Internal Revenue Service for its unpaid taxes. He also promoted Erin...
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