Initially, petitioner contends that respondent was barred from assessing sales and use taxes for the taxable period March 1, 1972 through August 31, 1972 by subdivision (b) of section 1147 of the Tax Law which prohibits the assessment of additional tax after the expiration of more than three years from the date of the filing of a return. On September 4, 1975 petitioner signed an agreement extending...
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