Kaskel 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 respondent which sustained a gift tax imposed under Tax Law article 26-A.

Petitioner made certain gifts during the quarter ending September 1976 but did not file a gift tax return. She made gifts for the following quarter and filed a New York State resident return, but indicated her address as Miami Beach, Florida. The Department of Taxation and Finance served notices of deficiency for the final two quarters of 1976, computed…