Bernstein v. Commissioner of Taxation & Finance

—Mercure, J.

Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law § 2016) to review a determination of respondent Tax Appeals Tribunal which sustained personal income tax assessments imposed under Tax Law article 22.

By this CPLR article 78 proceeding, petitioners challenge a determination of respondent Tax Appeals Tribunal sustaining notices of deficiency of the Department of Taxation and Finance for personal income taxes due during the 1984 and 1985 tax years. For the tax year 1984, out of a total income of $13,405,710, petitioners* reported $11,244,954 as…