Petitioner was, during the time period relevant to this appeal, the president and one of two shareholders of a corporation that owned and operated Petak's, a delicatessen and gourmet shop on Madison Avenue in New York City. In July 1987, petitioner and the corporation were notified that Petak's was to be the subject of a field audit, conducted by the New York City Department of Finance, to determine its compliance with the sales and use...
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