FISHER, Judge.
On July 8, 1992, the Petitioner, James T. Bailey, Jr., was arrested in Hamilton County while selling a ten pound brick of marijuana. Two days later, the Respondent, the Indiana Department of State Revenue (the Department) issued a jeopardy assessment and demand against Bailey for $178,200 in controlled substance excise tax (CSET) liability pursuant to IND. CODE 6-7-3. Because Bailey had not paid the tax when it was due, the Department also assessed...
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