JOANOS, Chief Judge.
This is an appeal from assessment of a tax deficiency in the amount of $270,799.02, based on the confiscation of 171 marijuana plants from the property of appellant Joe Hatch. Appellant contends the Department of Revenue failed to establish a fair "estimated retail value" of the marijuana plants, and failed to prove that unprocessed marijuana has any value. We reverse.
The record reflects that after the marijuana at issue was discovered...
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