Zacher v. Michael

Determination of respondent New York City Commissioner of Finance, dated March 17, 1982, assessing petitioner under the city’s Unincorporated Business Income Tax Law (Administrative Code of the City of New York, § S46-2.0) in the principal amount of $87,744.69, plus interest (less a credit of $6,297.42 for personal income tax overpayment), is confirmed, without costs. The critical question in the case is whether the respondent’s determination that petitioners’ testator (hereinafter petitioner) was not an employee of CBS (and certain other companies) during the tax years was supported by…