OPINION
WOOD, Chief Judge.
After an audit, the Bureau of Revenue assessed Archuleta for gross receipts tax, penalty and interest for the audit period. Archuleta protested the assessment. The audit was reworked. This resulted in an abatement of a portion of the assessment. A formal hearing was held as to Archuleta's liability for the assessment remaining after the abatement. The Commissioner of Revenue denied the protest as to the reduced amount of the assessment...
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