During the period involved herein petitioners owned and operated J & G Food Shop in Garden City Park, New York. On February 5, 1975, the audit division of the State Sales Tax Bureau issued a notice of determination and demand for payment of sales tax due for the period March 1, 1969 through February 28, 1974 in the amount of $37,418.60 plus interest and penalties. This figure was later revised by the audit division to $35,440.53. The statute pursuant to which petitioners...
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