Lahtinen, J.
An audit of petitioner's nonresident and part-year resident New York State tax returns resulted in respondent Department of Taxation and Finance issuing a notice of deficiency of personal income taxes for the years 2001, 2002 and 2003. The Department concluded that, during such time, petitioner had spent more than 183 days in New York and maintained a permanent place of abode in the state. Thus, he was considered by the Department to be a statutory resident...
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