Petitioner purchased a restaurant known as "The Red Lion" from Darbo, Inc. On November 30, 1979, the Audit Division of the Department of Taxation and Finance received a notification of sale, transfer or assignment in bulk from petitioner; the scheduled date of the sale was December 10, 1979. On December 7, 1979, the Audit Division issued a notice of claim alerting petitioner to a possible claim for State and local sales and use taxes...
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