Argiro v. Gallman

The petitioner is engaged in the occupation of industrial designer ¡and for the years 1961, 1962, ¡arid 1963 he specialized in the design of toys for appropriate clients having an interest in ¡the production and sale of toys. The petitioner maintains that he ¡should be exempt from the tax assessment because he is a member of a profession within the purview of subdivision (e) of section 703 of the Tax Law.

The decision of the State Tax Commission makes no finding as to whether or not the occupation of the petitioner is generally exempt from the unincorporated business fax but simply recites…