FISHER, Judge.
The Petitioner, Zinat Safayan (Safayan), appeals the final determination of the Respondent, the Indiana Department of State Revenue (the Department), assessing Safayan with gross retail tax (sales tax) pursuant to IND. CODE 6-2.5-9-3 and withholding tax pursuant to IND. CODE 6-3-4-8, plus penalties and interest, for the years 1989, 1990, and 1991 (the years in issue). The Department assessed Safayan as president of G.D.G.F., Inc. (the Corporation)....
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