New York makes it clear in a recent advisory opinion that the utilities tax imposed under Sec. 186-a is a tax on a seller’s gross receipts without a deduction for tax passed through to the purchasing vendor. Sec. 186 allows a utility to include a charge, lumped in or separately stated on the invoice, for taxes on a sale of natural gas. Regardless if the utility includes a charge for tax, the utility must remit tax calculated on total receipts. Sales of natural gas to an electricity generating facility are taxable. (TSB-A-04(9)C, May 24, 2004.)