From the record, it would appear that petitioner is primarily engaged in the wholesale business of selling egg containers. Those products which were delivered by petitioner were done so by the use of four vehicles, and by another five to seven vehicles to a more limited extent.
On April 28, 1978, the Audit Division of the New York State Department of Taxation and Finance assessed petitioner with an additional highway use tax in the amount of $22,964.83, plus interest...
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