J.R. Corelli Associates, Inc. v. Director

The issue presented by this appeal is whether a vendor which accepts a tax exemption certificate from a purchaser based on the vendor’s misinterpretation of the applicable law is relieved of liability for collection of the sales tax.

Plaintiff J.R. Corelli Associates, Inc. is a corporation involved in selling, leasing and repairing stretch-type limousines. As a result of an audit, the Division of Taxation issued a notice of assessment to plaintiff for an additional sales tax liability. The part of the assessment in controversy consists of taxes on the labor portion of repair bills on vehicles…