Menin v. Tully

— 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 sustained a deficiency assessment against petitioner for unincorporated business taxes for the years 1964 through 1970 and 1972 through 1974. After a hearing, respondent concluded that petitioner was an independent contractor with respect to all his income received from insurance companies which he represented. Petitioner reported his occupation to be that of estate planning. During the years…