Petitioner was engaged in the business of distributing and reselling petroleum products in New York. As the result of a 1985 audit, respondents determined that petitioner owed $2,833,337.35 in motor fuel taxes together with penalties and interest for the period of October 1, 1982 through October 31, 1984. Petitioner thereafter commenced this CPLR article 78 proceeding in this Court seeking review of that determination.
Respondents...
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