Heron v. Division of Taxation of the Department of Taxation & Finance

—Judgment unanimously modified on the law and as modified affirmed without costs in accordance with the following Memorandum: In January 1985 defendant served plaintiffs with notices of determination and demand holding them personally liable for taxes, penalties and interest incurred by Heron Automotive Service, Inc. Defendant filed collection warrants against plaintiffs in January and April 1985. Plaintiffs challenged the determinations by commencing this action in April 1993 seeking a declaration that the collection warrants were null and void and other incidental relief. Defendant moved to…