STEIN, J.
This proceeding concerns petitioner's request for a refund of certain sales tax payments that petitioner made in New York between 1997 and 2003. Petitioner is a home improvement retailer that operates throughout the United States, including New York. During the period in question, petitioner had private-label credit card agreements with two third-party finance companies. In accordance with those agreements, the finance companies issued credit cards bearing...
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