Petitioner owns and operates a small grocery store in the Village of Painted Post, Steuben County. In August of 1975, representatives of the Audit Division of the Department of Taxation and Finance (Department) commenced an audit of petitioner for the period December 1972 through May 1976. They concluded that petitioner's books and records were not up to date and were otherwise insufficient upon which to base an audit. The auditors decided...
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