An Administrative Law Judge has held that sales tax was properly assessed on security guard services provided at construction sites for contractors working on projects for the New York City School Construction Authority. Matter of Crown Security, LLC, DTA Nos. 824873, 824957 (N.Y.S. Div. of Tax App., May 1, 2014). In 2009, Crown Security had been advised by the Construction Authority and by the Department that its services were subject to tax, and security services are included within the enumerated services subject to New York sales tax under Tax Law § 1105(c)(8). The ALJ found that exemption certificates provided by the contractor customers could not be relied upon because they all indicated they were provided for the purchase of tangible personal property, rather than security services; some did not identify Crown Security or were undated; and those that were dated were prior to Crown Security having been advised that its services were subject to tax, so they could not have been relied upon in good faith, as is required under Sales Tax Reg. § 532.4(b)(2).