In 1986, petitioner, a not-for-profit State-wide organization for licensed dentists, requested a declaratory ruling from respondent on the taxability of the sale to dentists of orthodontic space maintainers, retainers, positioners and habit-breaking appliances. Petitioner claimed that the devices were entitled to the exemption from sales and use taxes provided for by Tax Law § 1115 (a) (3) and (4). On February 10, 1987, respondent issued...
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