GUNTER, Justice.
This is an appeal from a summary judgment granted in the trial court in favor of the Revenue Commissioner in a sales tax case. The commissioner assessed a deficiency plus penalty and interest against the taxpayer, the taxpayer appealed the assessment to superior court pursuant to Code Ann. § 92-8446, both sides moved for summary judgment, and the commissioner's motion was granted and the taxpayer's motion was denied. The issues for decision are...
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