Petitioner, an operator of commercial aircraft from Binghamton and Elmira, New York, to major metropolitan communities in the eastern seaboard States as well as to Cleveland, Ohio, was audited by State tax authorities in 1976. Following the audit, a notice of determination and demand for payment of use taxes in the sum of $148,446.18 covering the period March 1, 1973 through February 29, 1976 was issued to petitioner. In addition to challenging this deficiency, petitioner...
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