RICHARDS, J. pro tem.
Defendant appeals from a judgment against him and in favor of the plaintiff in the amount of $130,264.49, together with interest and costs, in an action to collect motor vehicle fuel license taxes under the Motor Vehicle Fuel License Tax Law based upon a jeopardy determination made by the State Board of Equalization pursuant to article 4, chapter 5, part 2, division 2 of the Revenue and Taxation Code.
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