DUDLEY, Justice.
The appellants refused to submit to an audit of their tax records. The Commissioner of Revenues made estimated determinations of the sales tax and income tax due which appellants contested before the Board of Hearings and Appeals of the Revenue Division of the Department of Finance and Administration. The Board upheld the commissioner's estimate and appellants did not appeal. The commissioner then filed Certificates of Indebtedness for the delinquent...
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