Petitioner SIN, Inc. (SIN) operates a Spanish language television network and recording studio. The respondent Department of Finance of the City of New York assessed a deficiency of $98,503.28 in commercial rent tax against SIN for the tax years June 1, 1980 through May 31, 1983, based on expenditures by SIN during those years totaling $1,446,166 for improvements to its leased commercial space at 460...
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