Pochter v. State Tax Commission

— 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 the State Tax Commission which sustained an unincorporated business tax assessment under article 23 of the Tax Law for the years 1966 through 1972. The issue presented by this proceeding is whether the record contains substantial evidence to support State Tax Commission’s determination that petitioner’s business activities as an outside commission salesman for two wholesale apparel firms constituted the carrying on of an…