The facts giving rise to this dispute date back to 1969. Petitioners were audited by the Sales Tax Bureau of the Department of Taxation and Finance and were informed by the auditors that the rent they charged their members for cabanas was nontaxable. It appears that respondent changed its position and indicated in 1974 that sales taxes would be assessed on cabana rentals, which it did for the tax years beginning in 1971. This assessment was...
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