American Cyanamid & Chemical Corp. v. Joseph

New York City’s local retail sales tax statute (Administrative Code of City of New York, ch. 41, tit. N), imposes the tax on the purchaser but requires that it “ be paid by the purchaser to the vendor as trustee for and on account of the city ” and makes the vendor ‘ ‘ liable for the collection thereof and for the tax ” (Administrative Code, § N41-2.0). Since this is a “ consumer’s tax ” and the sales taxed are such only as are not for resale, the law (§ N41-2.0, subd. i) provides for a “ certificate * * * for resale ’ ’ which may be issued by any vendee who is properly registered with the…