Stein, J.
Cai Restaurant, Inc. operates a restaurant, pizzeria, wine cellar and steak house known as Christiano's, and petitioner is its chairperson and/or chief executive officer. In 2006, the Department of Taxation and Finance conducted a field audit of Cai's business operations in connection with outstanding sales and use taxes owed for the period September 1, 2003 through May 31, 2006. After the audit, the Department issued a notice of determination assessing...
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