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Building's address. In addition, Mr. Spera made representations
to third parties that the Ashland Building was Huntersfield's
primary place of business: On a December 8, 1987, application
package to New York State Electric & Gas for electric service to
the Ashland Building, signed by Mr. Spera, the business and
customer name identified for billing purposes is Huntersfield; in
a petition for the judicial dissolution of Huntersfield, Mr.
Spera stated that the principal place of business of Huntersfield
was the Ashland Building. An admission by Mr. Spera also
supports respondent's argument that other entities used the
Ashland Building. Peter Toporowski, a revenue agent, testified
that in July 1993 he inspected a three-story building on the
Ashland property, and that on the first floor he observed
leftover construction equipment, a bulldozer, a workbench, and
tools. In response to Mr. Toporowski's inquiry as to who owned
the aforementioned equipment, Mr. Spera stated that the equipment
belonged to a couple of dissolved corporations. At trial,
Mr. Spera claimed, among other things, that GRC charged
Huntersfield rent for the storage of construction materials and
that Huntersfield's offices were located elsewhere. However,
other than Mr. Spera's unsubstantiated testimony, petitioners
presented no supporting documentation or testimony. Moreover,
while GRC's depreciation of the Ashland Building is seemingly
consistent with its ownership and use of the Ashland Building,
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