ON DENIAL OF PETITION FOR REHEARING
HUNTLEY, Justice.
In June of 1979 Fred and Mary Tarbox, doing business as M & K Sales, a used car proprietorship, were issued a Notice of Deficiency Determination by the Idaho Tax Commission. Most of the tax asserted in the deficiency notice is sales tax on the sales of licensed motor vehicles; however the assessment also includes a fifty percent fraud penalty. The penalty was imposed because although the Tarboxes...
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