OPINION
HATHAWAY, Judge.
Plaintiff/appellant brought this special action in the superior court in Pima County against the Arizona Department of Revenue requesting an order that the defendant issue its certificate pursuant to A.R.S. § 43-1362 or, in the alternative, find that by reason of the failure of defendant to advise plaintiff of any tax due, plaintiff had waived all tax liability. A defense motion to dismiss was heard by the court and treated as...
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