Fishel v. State Tax Commission

This is a proceeding pursuant to CPLR article 78 to review a determination of the State Tax Commission which denied the petitioners’ claim for refund of unincorporated business tax paid for the year 1970, as well as their petition for redetermination of a notice of deficiency for unincorporated business taxes for the years 1970 and 1971, and which directed the Income Tax Bureau to issue a notice of deficiency against the petitioners for the year 1971 to include the disallowance of the deduction for reasonable compensation of personal services with interest.

The petitioners’ decedent was a…