Petitioner, engaged in the sale and servicing of new and used automobiles, filed sales and use tax returns for December, 1979 and January, February and March, 1980 without remitting $108,507.41 due for said months. On October 23, 1980, the business was sold and $110,000, representing all unpaid taxes and a portion of unpaid penalty and interest, was remitted to the Department of Taxation and Finance. The unpaid balance of penalty and interest was subsequently paid under protest...
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