Petitioner instituted this CPLR article 78 proceeding to review a determination of respondent which held petitioner liable for State and New York City sales and use tax for, inter alia, the services performed by petitioner's art directors and retouchers. The facts in this case are undisputed.
Petitioner is engaged in the business of producing catalogs for department stores in the United States and Canada. As part of the production...
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