The Department of Taxation and Finance conducted a sales and use tax audit of Robert Landau Associates, Ltd. (hereinafter RLA) for the period December 1, 1980 through May 31, 1984. Because of RLA's undisputed failure to adequately comply with the Department's requests for various records, the Department elected to perform a test audit for a one-month representative period, thereafter reduced by agreement to a review of RLA's larger sales for...
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