The New York State Tax Appeals Tribunal has affirmed the decision of an ALJ that a car dealership could not obtain a refund of sales tax paid to New York instead of to Connecticut on extended warranties -- although the Connecticut Department of Revenue had audited it and determined that the tax was owed to Connecticut -- because it had failed to first refund the amounts to its customers. Matter of Stamford Subaru, LLC, DTA No. 826071 (N.Y.S. Tax App. Trib., Nov. 23, 2016). The Tribunal relied on Tax Law 1139(a), which mandates that no refund is available for tax that was "collected from a customer" unless the amount is first refunded to the customer, and rejected the dealership's arguments that it had fulfilled the repayment requirement by an assumption of the obligation of its customers to Connecticut for the tax.