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  5. 149 A.D.2d 824 (1989)
 

MATTER OF ATLAS LINEN SUPPLY CO., INC. v. CHU

149 A.D.2d 824 (1989)

In the Matter of Atlas Linen Supply Company, Inc., Petitioner, v. Roderick G. W. Chu, as Commissioner of The New York State Department of Taxation and Finance, Respondent

Appellate Division of the Supreme Court of the State of New York, Third Department.

April 20, 1989

Harvey, J.

The principal issue in this proceeding is whether substantial evidence supports the State Tax Commission's determination that petitioner's purchases of linens and garments for use in providing laundering services to hospitals were not purchases "for resale" (Tax Law § 1101 [b] [4] [i] [A]) and were thus subject to taxation (see, Tax Law § 1105 [a]). Petitioner is in the business of furnishing linen laundry services to hospitals...

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