A New York State ALJ held that the New York State Tax Department properly revoked a store owner's Sales Tax Certificate of Authority. Matter of Clinton Delicatessen, Inc., DTA No. 827615 (N.Y.S. Div. of Tax App., May 25, 2017). The store owner had failed to respond to a Notice of Determination for sales tax, resulting in an unpaid final liability of approximately $779,000. The ALJ concluded that, consistent with the requirements of Tax Law 1134(a)(4)(A), the Department had properly notified the taxpayer of the proposed revocation for willful failure to pay the tax and, since the taxpayer could no longer challenge the final sales tax liability, it was incumbent on the taxpayer to raise a defense to revocation, which the taxpayer failed to do.