DEEN, Presiding Judge.
1. Although the ultimate liability for payment of sales and use tax falls upon the purchaser (Code § 92-3402a), and although in the event of failure to pay the Revenue Commissioner may proceed against either purchaser or seller, it is nevertheless the intent of the law that the seller or "dealer" is the entity responsible for collecting and forwarding the tax (Code § 92-3405a) and his failure to do so subjects him to both civil and...
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