Petitioner previously operated a gas station which was the subject of a sales tax audit in 1982. On June 18, 1982, the Department of Taxation and Finance sent petitioner, by certified mail, a notice of determination and demand for payment of sales and use taxes due in the amount of $61,295.18, including interest and penalties. The document was returned as undeliverable, with a notation that the addressee had moved. On June 21, 1982, the Department...
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