The facts are undisputed. Petitioner manufactures wallpaper using engraved metal cylinders to print the patterns on the paper. Petitioner purchased blank cylinders out of State and sent them to another out-of-State company for engraving. After they were engraved, petitioner brought the engraved cylinders into New York and used them in its factory. As a result of an audit for the period from June 1, 1976 to May 31, 1979, respondent assessed a compensating use tax against petitioner...
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