On September 17, 1986, the Department of Taxation and Finance (hereinafter the Department) issued a notice of determination and demand against petitioner for additional sales tax, penalties and interest in the amount of $496,418.94 for the period June 1, 1983 to May 31, 1985. A copy of this notice was sent by certified mail to petitioner at its last known address, 5622 Church Avenue, Brooklyn, New York 11203 (see, Tax Law § 1138...
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