The facts are not in dispute. Petitioner, a foreign corporation incorporated in the State of Illinois, is licensed to do business in the State of New York. Petitioner timely filed corporate franchise tax reports for the year 1971 pursuant to article 9-A of the Tax Law. In November, 1973, the New York State Department of Taxation and Finance (department) issued a notice of deficiency to petitioner in the amount of $124,308.51 plus interest. This was for an additional license...
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