Dalenz v. State Tax Commission

Proceeding under article 78 of the Civil Practice Act to review a determination of the State Tax Commission which denied petitioner’s application for refund of personal income taxes paid for the years 1951 and 1952. Petitioner, a resident of Connecticut, was employed as a securities salesman and paid a salary and commissions for services rendered his employer both within and without the State of New York. Petitioner contends (1) that since all orders upon which he received commissions were executed at his employer’s New Jersey office, no part of his commissions constituted “gross income from…