The letters sent to petitioner by the City Department of Finance and the statements on the GCT returns for 1981 and 1982, permitting petitioner to file combined GCT returns with another corporation, did not preclude the Department from subsequently auditing those returns and, upon doing so, determining that the tax should not be computed on a combined basis, but rather separately. The Department had at all relevant times distinguished between "filing" and "audit" (see...
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