As pointed out by the Director, that admission charges are not property for sales and use tax purposes is made plain by the fact that the Legislature created an entirely separate provision in the Sales and Use Tax Act for admission charges. Only those services that are specifically delineated as taxable fall within the Sales and Use Tax Act. Admission to a sports facility is not included in that list. Thus, amounts charged for admission to sports events were treated differently than amounts charged for personal property or services. But before we focus on that subsection, we are constrained to add the following comments.
Taxation is truly an arcane subject.
In construing a section, a missed word or comma can easily change the result reached. However, candor requires us to admit that we could be wrong. Nets professional basketball games, and the admission charges to attend such events, clearly fall within the exception to the exemption. These provisions do not authorize the Authority to provide exclusive benefits to elementary or secondary schools. While New York's sales tax statute served as the model for our statutory scheme, its interpretive decisions are, of course, not binding or controlling.