KAVANAGH, J.
In 1997, petitioner, who owns and operates Alvin's Wine and Liquor, Inc. in Bronx County, received notification from the Department of Taxation and Finance that it would perform an audit of sales tax returns filed on behalf of the business for the three-year period beginning in December 1994. As part of the audit, petitioner was requested to provide all records regarding purchases and sales made by the business during this three-year period, including...
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