The Audit Division of the Department of Taxation and Finance conducted a sales and use tax audit of petitioner Vebol Edibles, Inc. operator of a coffee shop in New York City, for the period March 1, 1981 through February 29, 1984. Because Vebol was unable to provide cash register tapes, guest checks, cash ledgers or any other sales records for the audit period, the Audit Division resorted to the use of a two-day observation test, conducted...
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