T. J. Gulf, Inc. v. New York State Tax Commission

*315On February 9, 1981, petitioner sent to respondent a notice of its proposed purchase of a gasoline service station, pursuant to Tax Law § 1141 (c). According to the Audit Division of the Department of Taxation and Finance, on February 18, 1981, it sent to petitioner a notice that a possible claim for unpaid sales taxes existed (see, Tax law § 1141 [c]). Petitioner contends that it never received this notice. The closing of petitioner’s purchase of the service station occurred on March 2, 1981; subsequently, petitioner received a demand for payment of sales taxes which had been unpaid by the…