Bower v. New York State Tax Commission

Proceeding pursuant to CPLR article 78 (transferred to this court by order of the Supreme Court at Special Term, entered in Albany County) to review determinations of the State Tax Commission sustaining personal income tax assessments imposed under sections 612 and 617 of the Tax Law. Petitioners, all partners or spouses of partners in the same New York City law firm, initially contend that, except with respect to petition*933ers Bartlett, the respondent commission is precluded from challenging their petitions seeking redetermination of the deficiencies asserted against them for it failed to…