PETERS, J.P.
Petitioner Lev Wolkowicki is the manager of petitioner Winners Garage, Inc., a New York corporation that leases taxicabs to drivers in the City of New York. In October 2007, the Department of Taxation and Finance audited Winners Garage and determined that it had failed to pay sales and use taxes in the amount of $211,907.10 from December 1, 2004 to August 31, 2007.
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