OPINION
PER CURIAM:
FACTS
Jim L. Shetakis Distributing Co., Inc., d/b/a Shetakis Wholesalers ("Shetakis"), is a wholesaler who sells food and non-food items to hotels, restaurants and other businesses involved in food preparation. The Department of Taxation (Department) conducted an audit of Shetakis for the period of April 30, 1980, through March 31, 1983. The audit was conducted by the use of two "test periods." The Department originally...
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