Fredkin v. State Tax Commission

The taxpayers filed a timely joint individual income tax return for the calendar year 1971, and the Commissioner of Corporations and Taxation gave notice of intention to assess an additional tax. On November 16, 1972, the taxpayers filed a timely application for abatement of the additional tax, and on November 17, 1972, the State Tax Commission sent them by certified mail a decision denying the application. On January 8, 1973, the Commission denied a second application filed on January 4, and on January 19, 1973, it denied a hearing on a motion to reconsider dated January 9. On February…