Tinkler v. Chu

Yesawich, Jr., J.

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 respondent State Tax Commission which sustained an unincorporated business income tax assessment imposed under Tax Law article 23.

Petitioner challenges a May 1980 notice of deficiency issued against him by the State Department of Taxation and Finance which asserted that unincorporated business income taxes were *492payable for the years 1975 through 1978. The predicate for the assessment was that his employment…