Petitioner Scholastic Specialty Corporation (hereinafter SSC) produces and sells parochial school uniforms in the metropolitan New York City area. While it sells a portion of its products to retailers for resale (a nontaxable transaction [see, Tax Law § 1105 (a)]), pursuant to agreements with various parochial schools it also comes into those schools and sells uniforms directly to the students. As SSC now apparently concedes, these...
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