OPINION
ROBERTSON, Judge.
Max D. Horrall brings this belated appeal of his conviction of Possession of Marijuana, a class D felony, pursuant to Ind.Post-Conviction Rule 2(3). Horrall was prosecuted for this offense after the Indiana Department of Revenue had assessed a Controlled Substance Excise Tax [CSET] against him in an amount in excess of $12,000.00 with respect to the marijuana in question. The sole issue raised on appeal may be restated as:
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