Petitioner purchased an ongoing business in February 1982 subject to Tax Law § 1141 (c) as a bulk sale. Respondent Department of Taxation and Finance issued a notice of determination and demand for payment of sales and use taxes to petitioner in May 1982 in the total amount of $73,432.75, including penalties and interest. Petitioner neither paid nor filed an administrative objection to the tax, prompting the Department to issue a warrant...
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