During the relevant time periods, petitioner was a private registered business school in New York City. It participated in the Tuition Assistance Program (hereinafter TAP) administered by respondent New York State Higher Education Services Corporation (hereinafter HESC) (see, Education Law §§ 652, 667, 5002). In order to be eligible for TAP, an institution such as petitioner was required to, inter alia, comply with...
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