Petitioner, an advertising agency, is engaged in the preparation and production of advertising materials, such as catalogues and brochures, as well as the placement of advertisements in the media. The Department of Taxation and Finance audited petitioner's books for the period June 1, 1976 to August 31, 1979. The Department concluded that petitioner had failed to collect sales tax from its customers for "artwork and retouching done by ...
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