Rosen said he had done nothing wrong.

“They are just looking for tax revenue, let’s be honest,” he said of the state. “But I want to move on. I have the money to pay.”

Gelfand’s two companies bought and sold more than 30 works for more than a total $1 million using certificates designating that they would be resold, Schneiderman said. From 2005 to 2013, the companies paid no sales or use tax -- a tax on items put to personal use after saying they’d be resold -- while displaying some of the pieces in Gelfand’s home, he said.

The Gagosian Gallery, where Gelfand works, isn’t accused of wrongdoing. Gelfand’s lawyer said she doesn’t “necessarily agree” with Schneiderman’s conclusions.

“These were purchases through a personal company and had nothing to do with the Gagosian Gallery,” said Jo Backer Laird, a lawyer who represents Gelfand. “The works were fully intended to be resold. In fact, efforts were made to resell them. Victoria settled because of the department’s position that works that are intended for resale but are exhibited in the home of the taxpayer are subject to sales and use tax.”

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