Petitioner admitted that upon receipt of the notices for payment of sales and use taxes, which were dated December 29, 1987, he "did nothing" until July 1988 when he received a collection notice from respondent. His letter requesting an administrative hearing was dated July 25, 1988 and was therefore well past the 90-day time period for requests for review provided by Tax Law § 1138 (a) (1) (see, Matter of Halperin v Chu,
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