The publisher of financial periodicals failed to meet its burden of proof to show that it did not bundle its sale of nontaxable periodicals with sales of taxable products such as information services and, therefore, was held liable for estimated additional sales tax on its subscription charges. Matter of Institutional Investor, Inc., DTA No. 826331 (N.Y.S. Div. of Tax App., June 23, 2016). The taxpayer claimed that it primarily sold a print version of a financial newsletter, along with an online PDF version of the newsletter, but the Department found that various other products were also being offered, and the taxpayer failed to adequately respond to audit inquiries about those products. The ALJ also rejected the claim that the Department should be estopped from assessing additional sales tax based on the results of a prior audit, noting that no evidence was adduced by the taxpayer to prove that subscription sales were reviewed by the Department in that prior audit.