Petitioner operates a restaurant in New York City which was the subject of an extended sales tax audit in 1981. On October 20, 1981, the Department of Taxation and Finance (hereinafter Tax Department) sent petitioner, by certified mail, a correctly addressed notice of sales tax deficiency in the amount of $59,957.63 including penalties and interest pursuant to section 1147 (subd [a], par [1]) of the Tax Law. The assessment covered the period from September 1, 1977 to August...
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