The issue in this proceeding is whether substantial evidence supports the determination by respondents that medical equipment and supplies purchased by petitioner for use in its respiratory therapy services were not purchases "for resale" (Tax Law § 1101 [b] [4] [i] [A]) and were thus subject to taxation (see, Tax Law § 1105 [a]; see also, Tax Law § 1115 [a] [3] [purchases of medical supplies and equipment for performing...
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