In August, 1980, Blanchard Management Corp. (Blanchard) owed the State of New York more than $200,000 in sales tax arrears under article 28 of the Tax Law. The commission learned that Blanchard was owed money by Operation Open City (Open City) and, on August 18, 1980, the commission served a tax collector's levy on Open City directing it to pay over to the commission the debt owed Blanchard. Open City did nothing in response to this levy. On August 21, 1980, Blanchard entered...
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