Megson 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 a determination of the State Tax Commission which partially sustained a personal income tax assessment imposed pursuant to article 22 of the Tax Law.

On January 15, 1960, petitioner* and Reino Hyyppa entered into a written partnership agreement for the purpose of conducting a surveying and engineering business in the State of Connecticut. The agreement provided for the withdrawal from the partnership by one of the partners and for the sale of his…