New York Supreme Court September 5, 1967 (Fargnoli v. Murphy)

Russell G. Hunt, J.

The petitioners seek to set aside assessments of income taxes for 1958, 1959 and 1960 upon the ground that the Statute of Limitations (Tax Law, § 373, subd. 4) had run. It appears that after an audit by the Federal Internal Revenue Bureau the latter made assessments for additional Federal income taxes due for the years stated above.