DUDLEY, Justice.
Appellant, Director of the Department of Finance and Administration, audited appellee's business and determined that the appellee taxpayer owed $8,337.26 in delinquent taxes and $1,989.78 in accrued interest. The assessment was based upon the director's determination that the taxpayer had not paid sales taxes on the sale of bermuda grass sod. The taxpayer paid the tax and interest under protest, and filed suit to challenge the director's application...
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