On March 17, 1983 the State Tax Commission issued to petitioner, a retail seller of boats and trailers, a notice of determination and demand for payment of sales and use taxes, charging petitioner with tax due pursuant to Tax Law § 1138 for the period June 1, 1977 to November 30, 1980 in the amount of $38,863.78, a penalty of $17,621.17 and interest. Petitioner was accorded amnesty under the tax amnesty program leaving in dispute...
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