PANNELL, Judge.
Paragraph (d) of Section 16 of the Retailers' and Consumers' Sales and Use Tax Act (Ga. L. 1951, pp. 360, 378; Code Ann. § 92-3427a) provides that "[i]n the event any dealer . . . makes a grossly incorrect report, or a report that is false or fraudulent it shall be the duty of the Commissioner to make an estimate for the taxable period of retail sales of such dealer, or of the gross proceeds from rentals or leases of tangible personal property...
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