WRIGHT, Presiding Judge.
Robert Dallas Burdette (taxpayer) appeals an order of the Montgomery County Circuit Court upholding two final assessments issued by the Department of Revenue (Department) on November 7, 1984, after proceedings before the Administrative Law Division of the Department in which he was found to owe unpaid income taxes for the years 1981 and 1982 in the amounts $4,195.52 and $4,214.80, respectively.
The taxpayer does not dispute either...
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