Per Curiam.
The only issue for the BTA's determination was whether the Tax Commissioner was correct in reducing the mandatory statutory penalty from fifteen percent to ten percent.
There is no dispute over the scope of the review by the BTA, nor that it is appellant's burden to show an abuse of the Tax Commissioner's discretion. It is clear that the abuse must be shown to be unreasonable, arbitrary and unconscionable. Jennings & Churella Constr...
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