STATE OF NEW YORK
TAX APPEALS TRIBUNAL
In the Matter of the Petition
DTA No. 806488
for Redetermination of a Deficiency or for Refund of
Personal Income Tax under Article 22 of the Tax Law and
of New York City Personal Income Tax under Chapter 46, :
Title T of the New York City Administrative Code for the
Years 1983 and 1984.
Petitioner Lynda Jurist, 888 Park Avenue, New York, New York 10021, filed an
exception to the determination of the Administrative Law Judge issued on December 31, 1992.
Petitioner appeared by Richard DeMarco, C.P.A. The Division of Taxation appeared by
William F. Collins, Esq. (Herbert Kamrass, Esq., of counsel).
Petitioner filed a brief in support of her exception. The Division of Taxation filed a letter
brief in response. Petitioner was given until April 19, 1993 to file a reply brief. No reply was
filed by petitioner and, therefore, the six-month period to issue this decision began on April 19,
1993. Petitioner's request for oral argument was denied.
The Tax Appeals Tribunal renders the following decision per curiam.
Whether petitioner met her burden to prove that no business was carried on in New York
FINDINGS OF FACT
We find the facts as determined by the Administrative Law Judge. These facts are set
The Division of Taxation ("Division") issued a Statement of Personal Income Tax Audit
Changes dated April 9, 1987 against petitioner, Lynda Jurist, asserting additional New York
State/City personal income taxes for 1983 and 1984 as follows:
Reliance Capital Advisors, Inc.
Taxable Income Previously Stated
Corrected Taxable Income
Tax on Above
Max Tax if Applicable