FISHER, Judge.
C & C Oil Co., Inc. (C & C Oil) originally appealed the Indiana Department of State Revenue's (Department) assessment of special fuel tax, interest, and penalties for the years 1984, 1985, 1986, and 1987, and motor carrier fuel use tax, interest, and penalties for the years 1985, 1986, and 1987. The Department's Letter of Findings, issued April 16, 1990, denied C & C Oil's timely protest of the Department's proposed assessments for the years...
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