On February 9, 1981, petitioner sent to respondent a notice of its proposed purchase of a gasoline service station, pursuant to Tax Law § 1141 (c). According to the Audit Division of the Department of Taxation and Finance, on February 18, 1981, it sent to petitioner a notice that a possible claim for unpaid sales taxes existed (see, Tax law § 1141 [c]). Petitioner contends that it...
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