The facts in this case are relatively undisputed. Petitioner is in the construction trucking business and, during the relevant time period, operated several diesel trucks to haul items such as stone and gravel to construction sites in the Syracuse area. Significantly, Tax Law § 503-a imposes a fuel use tax on the operators of "vehicular unit[s]" (see, Tax Law § 501 [3]) using the State's public highways, but allows a credit...
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