ZIMMERMAN, Justice:
Petitioner Larry J. Zissi seeks a writ of review of a decision of the State Tax Commission. The Commission assessed $44,000 in penalties and taxes against Zissi, finding that he had failed to pay the taxes that Utah's Illegal Drug Stamp Tax Act ("the Stamp Act") imposes on the purchase, acquisition, transportation, or importation of controlled substances. See Utah Code Ann. §§ 59-19-101 to -107. Before this court, Zissi challenges...
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