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Section 1105(c)(4) of the Tax Law imposes a tax on the services of storing all tangible personal property not held for sale in the regular course of business.
The term "storage" is defined in the Sales and Use Tax Regulations as " . . . the provision of a place for the safekeeping of goods, without regard to the manner of payment or length of time of the service. "20 NYCRR 527.6(a)
If the space rental agreement is not distinguished from the provision of storage space because the contract does not specify "a certain amount of footage in a specific location." The provision of storage space would be subject to tax.
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