Commodore Hotel, Inc. v. Gerosa

The Comptroller of the City of New York made a one-day check of petitioner’s records underlying its sales tax returns and found a deficiency for the day of a negligible amount. Tin’s amount was then multiplied over a three-year period and assessed as a deficiency against petitioner.

Petitioner challenges the validity of a one-day check as a predicate for assessing the deficiency, and argues that it has fully discharged its duty as an unpaid tax collector by keeping records which are abundantly sufficient and calculated to produce as accurate a return as is humanly possible. The comptroller…