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2001-2 N.Y. Tax Cas. J-1 (2001)

handle is hein.nytax/nytcas0047 and id is 1 raw text is: 2001 New York Tax Cases J-1 STATE OF NEW YORK DIVISION OF TAX APPEALS In the Matter of the Petition of ROBERT M. CIPOLLA DETERMINATION DTA NO. 817175 for Redetermination of a Deficiency or for Refund of New York State Personal Income Tax under Article 22 of the Tax Law and New York City Earnings Tax on Nonresidents under Chapter 19, Title 11 of the Administrative Code of the City of New York for the Years 1994 and 1995. Petitioner, Robert M. Cipolla, 7 Handol Lane, New Fairfield, Connecticut 06812, filed a petition for redetermination of a deficiency or for refund of New York State personal income tax under Article 22 of the Tax Law and New York City earnings tax on nonresidents under Chapter 19, Title 11 of the Administrative Code of the City of New York for the years 1994 and 1995. A hearing was held before Dennis M. Galliher, Administrative Law Judge, at the offices of the Division of Tax Appeals, 641 Lexington Avenue, New York, New York, on April 27, 2000 at 10:30 A.M., with all briefs to be submitted by July 28, 2000, which date commenced the six-month period for the issuance of this determination. Petitioner appeared by Fiorita, Komhaas and Van Houten, P.C. (Robert R. Van Houten, CPA). The Division of Taxation appeared by Barbara G. Billet, Esq. (Peter T. Gumaer, Esq., of counsel). ISSUE Whether petitioner has established entitlement to allocate a portion of his wage income for each of the years 1994 and 1995 outside of New York as non-New York source income not subject to taxation by New York. FINDINGS OF FACT 1. Petitioner is a resident of the State of Connecticut. He is employed by and is the vice- president of MUCIP, Inc. (MUCIP) which, during the years in issue was located in College Point (Queens), New York. During the years in issue, petitioner held 50 percent of MUCIP's stock and had his office with MUCIP in College Point, New York. MUCIP installs cable television in residential homes and wires and rewires apartment buildings and complexes on a contract basis, and also performs maintenance services for various cable companies.

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