An Administrative Law Judge rejected a Long Island horse boarding facility’s claim that its sales of horses and fees for horse boarding were exempt from sales tax. Matters of Theodore P. Demetriou and New Windsor Stables, Inc., DTA Nos. 824430 and 824431 (N.Y.S. Div. of Tax App., Dec. 12, 2013). Although the tax law exempts sales of tangible personal property (including sales of horses) by a commercial horse boarding operation, the ALJ found that the exemption did not apply to charges for boarding horses. The ALJ also held that the evidentiary record did not prove that the taxpayer’s horse boarding charges qualified for the sales tax exemption available to horse breeding operations, and did not demonstrate entitlement to another exemption available for sales of racehorses less than 24 months old.