Petitioner raises and sells rats and mice for use in research laboratories. Petitioner sought a refund of $18,668.50 in local and State sales taxes paid on feed and chemicals for its animals from June 1, 1976 to June 1, 1979 pursuant to section 1115 (subd [a], par [6]) of the Tax Law. Petitioner contended that its breeding of animals constituted farming within the meaning of the statute entitling it to a tax exemption. The Department of Taxation and Finance denied petitioner...
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