The questions presented herein are whether respondent Tax Appeals Tribunal properly determined that petitioners failed to sustain their burden that the tax audit methodology used was clearly erroneous and whether it properly sustained the imposition of the maximum penalty pursuant to Tax Law § 1145 (a) (3) (i) for failure to register as a sales tax vendor.
Prefatorily, we note that petitioner Del's Mini Deli, Inc. (hereinafter...
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