Sheahan v. Murphy

Proceeding under article 78 of the Civil Practice Act to review a determination of the State Tax Commission which affirmed assessments of unincorporated business taxes against petitioners under article 16-A of the Tax Law. The determination covers two periods, one from June 1, 1951 to August 31, 1951, and the other for the fiscal year ending August 31, 1952. The sole issue on this appeal is whether petitioners were engaged in the practice of a profession within the meaning of section 386 of the Tax Law. Petitioners were partners, and their activities have been characterized as “ Distribution…